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HomeMy WebLinkAbout94-06258 I, ,', I, 'I I' " ,I " ,..1 I " " I ,I " , I I I, ,,' J " " , I' ',' "I " I. " I I " I , ,I I' , I " ,I ."1 I , 'd ',1"1 ", I '! q \11 t: I , , I I, , , ;'11, I , ;;1 I I, I, , I, I/} <C ,j ,Ii I,,' 1,1 ,I '" , , " , I' , , ," .,I',"'! I f' ',,:pJ <';-::',\ ! f" i' i,',,'j; J] 'I", "j 'Ii , I \ I' , " 'i!~ , ,1,1 I , , '1 " I'" I' ,,'1 J J ,,, ,I ,I' 'i' .'; " ",' :1 ,.1 \" ,'~! '00 1.0 t'l.', ~ ,I ,1,1 :1 ':~ i~ I ill ;;~ ':11 ,!l~ , ::-\~ " I' i' I: t r j. 1" , , '" " :' 1,'111 , \ 1.'1' P.TITIO. PO. .. .Z PART. ORD.. .0. .1tM.~IGII p."'" DU.. AIID TEMPO-.-Y CUSTODY TO THE HONORABLE JUDGE(S): NOW COMES PETITIONER, ANN P. LUCAS and petitions this court for temporary and final protection orders under the Protec;tion from Abuse Act pursuant to 23 Pa.C.S. 56101 et seq. and as her grounds for this relief does say as follows: 1. On the November 4, 1994, Petltioner Ann P. Lucas conunenced this action for an Order for Protection From Abuse against Respondent, Charles A. Luc~s. 2. On November 21, 1994, the underlying Complaint for Divorce was discontinued by the filing of a Praecipe to discontinue by Charles A. Lucas, pursuant to a mutual effort by the partitis at reconciliation. 3. Your Petitioner and the Respondent are residing in this county at the marital home of the parties, being 4820 Charles Road, Hechanicsburg, Pennsylvania 17055. 4. Your Petitioner seeks a protective order under 35 P.S. S 10181 ~ ~ as amended for protection of hersslf and her four children, who range in age from ten years old to age nineteen. 5. The Petitioner Ann P. Lucas and Respondent Charl~. A. I,ucaa, have been married and living together for twenty-two years. 6. Your Petitioner is employed at the Pennsylvania Blue Shield. 7. Respondent is employed at the New Cumberland Army Depot in New Cumberland, Pennsylvania. 8. Throughout several years of the marriage there have been incidents in which Respondent showed a propensity for violence with Petitioner including one incident in which Respondent held a knife at Petitioner's throat in the prssence of other persons while at a party in Germany where ReBpondent was stationed at the time. 9. Respondent is highly conversant with guns and other weapons having been a trained member of special forces in Viet Nam and has been diagnosed as suffering from Post-Viet Nam P':.reS8 Syndrome. 10. Respondent continues to irrationally ins.ist that Petitioner is having an affair and has gone so far as to identify whQ be thinks the man is, allegedly tapping the person's phones by admission to Petitioner, call ing the man's place of business, having the person followed, and going about speaking in a rage about the alleged involvement, when in fact no such involvement by Petitioner exists in any way, shape or form. 11. Respondent has also been diagnosed as having the disease of alcoholism and was released from a hospital program for treatment of such disease Augu8t 28, 1994. 12, In late July, 1994 there wa~ an early morning incident referred to in Petitioner's first petition for ~FA, in which Respondent, obviously very upset, had brought a .45 caliber pistol into the bedroom. Petitioner was placed in imminent fear of her life by Respondent's action. 13. In early January, Respondent commented to petitioner that he had IS box of items which he intended to pass on to the couple's oldest son, should anything happen to him. When she asked Respondent what he meant, he said, "Well, you never know when something is going to happen to you when you confront oomeone." 14. Shortly thereafter, the couple's young daughter Mary observed her father performing a procedure with bullets in the garage at the marital residence and summoned your Petitioner. 15. On this occasion your Petitioner came to the garage to discover R~spondent loading a highly volatile substance, ie. mercury, into six bullets. When asked what he was doing, Respondent said, NOh it's just something I do." There are six members in the family. 16. Alarmed by what she saw, petitioner notified two Doctors--Ooctor Nolan who referred her to Dr. Penndorf and then on to the crisis center authorities including the Holy Spirit Hospital Crisis intervention center to institute commitment procedures. Respondent was able to pass through interviews with psychiatric staU to successfully be reloased that same evening without commitlllent. 17. Respondent is totally at ease with poUce and authorities, having been a gun dealer, having been through a hOlpital Itay in August, 1994 and having been a member of the U.S. special Forces in Viet Nam and elsewhere. These circumstances and hiB personality and demeanor placea Petitioner more in fear, because Respondent is able to hide his menace from others and convince people that he is harmless. 18. After the earlier commencement of a PFA Petition by petitioner, Respondent allegedly disposseued himself of all of his guns and of his gun business. However, in Petitioner's presence Respondent boasted to Hampton Township police Officer Gary Bonner, when the latter was there to pick up the mercury from Re~pondent, that "You know 1 could get a gun within an hour anytime I wanted one." petitioner believes Respondent could get away with anything he set his mind to do, until the damage is done and it's too late to intervene. 19. Aproximately four weeks ago, Reapondent told Petitioner that there were "new allegat.ions" against her from his sources whom he had hired to follow her and track her whereabouts. 20. Since the parties had previously agreed that if Charlee Lucas's "people" came to him with any new allegations Against Petitioner that he would allow Petitioner to confront them and dispute their allegations, she demanded that he produce his "sources" and their evidence so that she could prove otherwise. pstitioner st,ated that the only solution was divorce and Respondent physically grabbed her about the arms and shoulders and shook her roughly spilling her soft drink. 21. Numerous incidents recently indicate that the parties' children are feeling more atress and experiencing more emotional and physical health problems as a result of the atmosphere in the marital home. For example, the older son of the parties has recently made comments indicating extremely low self esteem and has quit college 5S a result of the stress in the family and the younger daughter of the parties has missed extensive days of school through illness. 22. Respondent continues to exhibit anger and rage at the supposed man involved in Respondent's delusion about an "affair", showing this in a drive with Petitioner in his truck in the last few days such to scare her through his angry handling of the vehicle. 23. In order to protect herself, Petitioner has consulted with Counsel and local police officers at the Hampton Township Police Department who know Charley Lucas and know the situation of his conduct. Said police authorities are unwilling to become involved as witnesses because they fully expect to be involved officially in enforcing a PFA Order. However, one police officer has recon~ended to both petitioner and her Counsel that she secure a full PFA removing Respondent from the marital home at the S8me time as the filing of a new divorce complaint by Petitioner, in order to give the police the authority they need to protect the family. 24. Both Petitioner and the Police authorities fully expect the situation to become too volatile to protect the lives of Petitioner and the children, once service is made of a divorce " complaint, unle.. there is issued and in place for service with the divorce complaint, a PFA order removing Respondent from the marital home, 25. On Wednesday, November 2, 1994 Petitioner received a threatening letter from Respondent's attorney which letter endeavored to intimidate her into moving out of the marital home of the parties, prior to your Petitioner's even being served with the cowplaint in first divorce action commenced by Respondent. 26. Respondent has stated numerous times that he is determined to stay in the marital home and to save it for hie children 6nd that he "Will not movel" all of which indicates to Petitioner that Respondent could react so violently that life and safety in the home environment cannot be maintained or protected unles. this Court grants an Order removing him from the marital premises. 27. Petitioner is so afraid of Respondent and his propensities, that she is afraid that even making this request for an order for PFA and eviction of Respondent, after the events of recent day. could provoke Respondent into violent conduct by the very commencement of this proceeding. 28. Respondent has become so obsessed with his delusion of an affair occurring that last weekend, he entered his parente' home in a rage and ranted about Petitioner's allegedly spending time with the man he claims she is having an affair with for several hours on Thursday evening, March 30, when your petitioner was at home with her children all of the time in question. 29. Petitioner and the parties' oldest son have heard him say he would have "the man's legs broken," referring to the man he claims she is having an affair with. Respondent's conduct is irrational, delusional and unpredictable. 30. By his conduct averred herein Respondent has used his physical, mental and emotional menace to place Petitioner in great fea~ for her life and in fear of imminent serious bodily injury for herself and her children. 31. Your Petitioner and her children are in immediate danger of further posaible vi~lence and a court order is necessary to protect them. 32. For these reasons, Petitioner fears that if advance Notice in any form is given to Respondent, or any attorney who may represent him prior to the entry of the Temporary Order, and if he informs Respondent of the action being taken, that this in itself could provoke violence in this matter. 33. Respondent is responsible to support Petitioner and the children of the parties. 34. Petitioner also requests temporary and permanent custody of the children of the parties in an accompanying Complaint for Divorce being filed with this Petition for Protection From Abuse Order. WHEREFORE plaintiff Heeke a temporary and final Order of Protection from Abuse, removing and evicting Respondent from the marital home of the parties and prohibiting Respondent from having any contact whatsoever with Petitioner, restraining Respondent from entering her place of employment, restraining Respondent from ,I' J'l , ~'l,; . coming near her in or at the marital reBidence in MechanicBburg or from haraBBing petitioner or the children in any way; plaintiff further doeB pray for an order for temporary and permanent lupport and cUltody of the children of the parti.1 and to Bet thil matter for a hearing before the court within ten days. VERIFICATION OF PETITION BY PLAINTIFF I verify that the Btatements made in thiB petition are true and correct. I underBtand that falBe BtatementB herein are made subject to the penalties of 18 Pa. C.S. Sec. 4904, relating to unsworn falBification to authorities. 11~-1 ~III J H c ,Y~ ~1l" j PAULETTE LUC~ PETITIONER - LUCAS PETITION FOR PFA: DATED: ~I / s / q j I ~ a:fJ;t1::iJ DAVID S. BRADY, ESQ. PA. BAR . 35928 OLDE ENGLISH GAP 845 SIR THOMAS COURT HARRISBURG, PA. 17109 (717) 541-4400 fAX . 541-4401 " 'I ," " III - E ... .... M ........ ' ~,.. ..1' .I"... :rr'~:S'.~ .. 'T- ~,). I)...: ..... ",,-. .,n + ""Ii l. 'J:u. . .> '.....(.." <:> dO .:.. . vs. I IN THE COURT or COMMON PLEAS I CUMBERLAND COUNTY, PENNSYLVANIA : 94 - q,/. l..J s'i' CIVIL ~ CHARLES A. LUCAS PLAIIft'IPP . . ANN P. LUCAS : DEPENDAR'1' : IN DIVORCE COMPLAINT IN DIVORCE COUNT I AND NOW, comes the PLAINTIFF, by Attorney JAMES H. BACH, and avers as follows: 1 . Plaintiff is CHARLES A. LUCAS , who currently resides at 4820 CHARLES ROAD. MECHANICSBURG. PA 17055 2. Defendant is ANN P. LUCAS who , currently resides at 4820 CHARLBS ROAD. MBCHANICSBURG. PA 17055 - 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on FEBRUARY 17, 1973 5. There have been no prior actions of divorce or annulment between the parties. 6. The marriage is irretrievably broken. 7. Plaintiff has been advised of the availability of counseling and also the Plaintiff may have the right to request that the Court require the parties to participate in counseling, and after being so advised, Plaintiff does not desire counseling. COUNT II e. The averments of Paragraphs 1 through 7 herein are hereby incorporated by reference thereto. t. The parties have acquired property during this marriage but have not been able to agree on its equitable distribution. 10. Plaintiff requests this Court to preserve Plaintiff's right to have all marital property of the parties equitably distributed. COUNT III 11. The averments of Paragraphs 1 through 10 herein, are hereby incorporated by reference thereto. 12. Plaintiff requests reasonable support for adequate maintenance. 13. Plaintiff requests this Court to preserve its rights to seek reasonable temporary alimony and additional sums as may become nece~sary from time to time hereafter, until final hearing and permanent alimony thereafter. COUNT IV 14. The averments of Paragraphs 1 through 13 herein are hereby incorporated by reference thereto. 15. Plaintiff has employed legal counsel, but is unable to pay the necessary and reasonable attorney fees for said counsel, and is unable to be sustained during the course of this litigation. WBBRBrORI, Plaintiff prays your Honorable Court to: (a) Enter a Decree in Divorce, divorcing Plaintiff from the bonds of matrimony theretofore existing between Plaintiff and Defendant. (b) Order equitable distribution of marital property. (c) Award alimony as the Court deems just and reasonable. Cd) Order payment of alimony pendente lite, counsel fees, costs of experts, appraiser, and other expenses as the Court deems just and reasonable. (e) Order such other relief as tha Court deems just and reasonable. ~ ~ . J ] .. .. ~~ ~~ 'VI '::., - J "" .' a 8 0 ~J" ',/\ , ~ '1\ .,,2lrio ~:r - .. '" "l":' - .. ~ ~ 1~' ,. ~ - ..' " ."... ,- \:;, " ~ ~j, ~ t ~ e ::I !::::;I ~ ~r: ...,~~ 51?' r:':;,.... ,.a '. ,'" 06,.-:, '... .,..:.:(,,)-.c (~~..C)~.... .'j ,...~;;.I , ,}' .:5',1) ... ,~'=' J!' , 01/101;:': ~':~~ I.....:;;,. c,o ....... . , ' , .' ( I , ~~' '-'...... ~ '., . If I ~) ":,i r \ ' , , , ~-- .... (N, f.. .IS' (!~ '7A..,..- II1M\1." COMMDHWIAU'M C>> "NNI"'WiIIA DI~"'NT or MlAU" mAL MCOIIDI lIT"< CUMBERLAND ~ DIVORCI Kl RIg~RD OlNNULMINT (CHECK ONE) 0 ITm JILl N1J_~ ITATI 'ILI DATI HUSBAND ..- ('iN') '_I t. DATI (AfotttItJ 01' 6 LUCAS ....TH COIJItI'f ..... ~I (.... fit,.... c.,.""., PA (Cumberland) .~ENNSYLVANIA 1 USUAL OCCUMTION ,t_ tDoJol 16 - 46 CHARLES A. ..IIOINCI ",..., fit n o. elf)( ,fdm, Of ., 4820 CHARLES ROAD, MECHANICSBURG, NU"'R e. RAeI OP THII 2 WHITI lUCK -- [] 0 OTHIRI"""" o WIFE SECURITY IlAIOIN NAIll ,'IIWtJ '_I IL_ I DATI '_I tDoJol - ANN LUCAS 01' 4 13 43 BLASCO P. ...... NtlDlNe. ",...,<</It.o CIIM .lorD. (, Jll,p COUII~ - It OUCI '-"_~I 4820 CHARLES ROAD, MECHANICSBURG, PA (Cumberland) .':.H PENNSYLVANIA NU...." I _I 14 UIUAL OCCU""TIOH 01' THII 1 WHITI lLACK OTHER 1!kMc1~1 -- IiSJ 0 0 TEACHERS' AIDE "-'CIDl' (C......) - (Jr.,. Ot'OIWiQI1 Country) " D,,",OI' '-I (Do,) - THII THII -- CUMBERLAND COUN'l'Y PENNSYLVANIA ......."'AGI 2 17 73 NU....r:w .11 NU,...,. OP OII'INDlNT " ~INTI" " DlCIIII. CUlANTID 10 CHII.OfIIIN THII CHILDREN UNOIPll' MUltllAND WI" orHl1II (Specl"" HUr:;D WI,. OTHI~ I_'IVI _01('1 4 2 IiJ 0 0 0 0 NUWI" Dl' HUIlAND WI" PUT CUlIlOO'f OTHI" (Specl"'l " LlGAL GNOUNOI '0flI CMU.DMN 10 0 0 0 Dt'JORCI 0flI ANNULMI"" CUlrooV at' DATI Of! OIC"'II (NattHl} (a." ,- 123 DATIIltlIIOfIIT liNT ,-I - 1- m vITAL "IC()N)a IIQNAI'UAlCW 'MAHICIlIIIINQ CLI"K ;. I . , i ill r j ~t ~ ~ ... - ~ ~ , , . NOV 4 1994 ~ CHARLES A. LUCAS PLAINTIFF IN 1HE COURT OF COMMON PLEAS CUMBERLAND COUN1Y . PENNSYLVANIA DOCKET NO. 94-6258 V. ANN ~. LUCAS DEFENDANT ACfION IN DIVORCE ANN P. LUCAS PETITIONER IN nm COURT OF COMMON PLEAS CUMBERLAND COUNlY PENNSYLVANIA DOCKET NO. 94-6258 V. CHARLES A, LUCAS RESPONDENT PROfECIlON FROM ABUSE AcnON 'fE&IPOJARY ORD)!Jl FQB lllOTHCDQN FJOM ABUSE. TDIPORARY I3f'TODY AND C~HtJ n SUPPORT AND NOW, this t( day of ~, upon presentation and consideration of the within Petition, the Court enters the following Temporary Protection Order: 1. The Respondent shall refrain from abusing, harassing or threatening Petitioner either physically, verbally, wherever she may be. 2. Respondent is excluded from coming near Petitioner in the marital residence in which the parties reside during the pendency of this Order. 3. Respondent is prohibited from having contact with Petitioner, including, but not limited to, being restrained from enterins the place of employment, business, or school of Petitioner. 4. Respondent is hereby notified that if he violates this Order, he may be held in indirect criminal contempt which is punishable by a fine not to exceed $1,000.00 and by a sentence of up to six months in !ail and by other possible relief, Consent of Petitioner to resume contact with Respondent shall not invalidate this Order. 5. Respondent is to surrender all firearms of any make or description whether such weapens are in or about the premises of the marital residence or at any other location, to the Hampden Township Police Department upon service of this Order. It is.~ er rdered ,that.,f1airn~- espondent Charle&"it.. 1 h eby o~red t pay temporary child support th,:ough th Y CerIa Co t'Y Dome c RelatJorIs Departmen, n the ar:notint of T e /' ndre Do s ($3oo.~)'per jtleek pending the .tommeoc:ement wit' te~'/' ys b P ioner of a ~tic Relations Depa(~5p"Support Ac' . ~/ 7. It is further Ordered that this order shall be enforced by any law enforcement agency in a county where a violation of this Order occurs within the Commonwealth of Pennsylvania. 8. A copy of this Order shall be served on the police department(s) in the jurisdiction where Petitioner resides and is employed. A certified copy of this Order shall immediately be filed in the police county registry of Protection Orders. 9. The Hampden Township Police Department or the Cumberland County Sheriff is directed to accept, serve and file any and all copies of this Petition with payment of costs, 10. This Order shall remain in full force and effect until the further Order of the Court. . II. ?.t.\......1I' i. ~".'lIll~.J ~.... '."''''1.~..,{,J~ .~ ~", ."d~p," o/iAt ~_..-lid 1-""'.'''~ ~......., ?,~i'lIt., ...ia., 01. '.,J , " , ' ..". en - ;,.')... Mj.o. .' '. ~~r..;1 [;( en ~ :..~, '\.. I :,~ ., - ~ -, ,.. ... " !n -",f' r. ";";14 "''''),'l.., -:r I ,> I~. t..) '" ... ~ '" ", " " ,.. '. . .. NOV'~ 1994cJ"" CHARLES A. LUCAS PLAINTIFF IN nm COURT OF COMMON PLEAS CUMBERLAND COUNTY PENNSYLVANIA DOCKET NO, 94-6258 V. ANN P. LUCAS DEFENDANT ACTION IN DIVORCE ANN P. LUCAS PETITIONER IN 1HE COURT OF COMMON PLEAS CUMBERLAND COUNTY PENNSYLVANIA DOCKET NO. 94-6258 V. CHARLES A. LUCAS RESPONDENT PROTECI10N FROM ABUSE ACI10N lJ!1T1'lON ~Oa PR<rrEcnO~ FRO~ ABU-SE 1'EMfgRARY (:USTODY AND SUPPORT TO THE HONORABLE JUDGE(S): NOW COMES PETITIONER, ANN P. LUCAS and petitions this coun for temporary and final protection orders un<ier the Protection from Abuse Act pursuant to 23 Pa,C.S, 56101 et seq, and as her grounds for this relief does say as follows: " 1. On th~ November 2, 1994, Respondent Charles A. Lucas commenced this action for divorce against P~titioner Ann P. Lucas. 2. Your Petitioner and the Respondent are residing in this county at the marital home of the parti~s, being 4820 Charles Road, Mechanicsburg, Pennsylvania 17055, 3. Your P~litioner s~~ks a prot~ctive ord~r under 35 P.S. S i0181 s:1 ~ as amended for prot~ction of herself and her four children, who range in age from ten years old to ag~ nin~t~en, 4. Th~ Pelilion~r Ann P. Lucas and Respond~nt Charles A. Lucas, have been married and living tog~th~r for twenty-on~ years. 5, Your Petitioner is employed at the Sporting Hill Elementary School in Mechanicsburg as a Teacher's Aide, 6. Respondent is employed at the New Cumberland Army Depot and is laid off from there pending a settlement with the Depot concerning a wrongful discharge action and he has a part lime job at the Zembo Mosque as a security officer and begins a part-lime job at UPS in Harrisburg November 4. 7. Throughout several years of the marriage there have been incidents in which Respondent showed a propensity for violence with Petitioner including one incident in which Respondent held a knife at Petitioner's throat in the presence of other persons while at a party in Germany . where Respondent was stationed at the .time, 8. In late july, 1994, Petitioner told Respondent she was going out to be with frilmds and attended a reunion with the family of one of her highschool classmates, one jerry Melcher, who is a person she had dated in high school and had not seen for twenty-five years, who was visiting from out of state. 9. There were ten family members present including Jerry's mother Ruth who has been a close friend of Petitioner's since high school. At the gathering the group played parchesi. Petitioner did not arrive home until 3:00 a.m., one hour after Charles arrived home from his security job. 10, Respondent is highly conversant with guns and other weapons having been a trained member of special forces in Viet Nam and has been diagnosed as suffering from Post-Viet Nam Stress Syndrome. He owns numerous guns and weapons and has sold guns to area police officers. 11. Respondent has also been diagnosed as having the desease of alcoholism and was released from a hospital program for treatment of such desease August 28, 1994, 12. In the late july, 1994 early morning incident referred to above, Petitioner went to bed and Respondent, obviously very upset, brought a .45 caliber pistol into the bedroom. Petitioner was placed in imminent fear of her . life by Respondent's action. 13. On that occasion, Petitioner was afraid to tell Respondent the truth of where she had been, knowing that mention of the former boyfriend's name could have set Respondent off, When she later told him where she had been, Respondent agreed that it had been wise of her not to tell him where she had been, indicating that he would have misunderstood. 14. On another occasion within the last two weeks, Petitioner has been giving Respondent the "evil eye" and has come up to her, nose to nose, gritting his teeth in such a way as to indicate he was barely holding control over himself and his conduct. 15. Petitioner is afraid to even request that Respondent be evicted from the marital home under the Protection From Abuse statute due to the expected volatility of Respondent's reaction to such an order and Petitioner was also reluctant to provoke violent conduct by the very commencement of this proceeding, because of her fear of Respondent and his propensities. 16, Respondent has been obcessed with the idea that Petitioner has been having an affair and hired a private eye to follow her when in fact there has been no such involvement by your Petitioner with any man. 17. On Wt:dnesday, November 2, 1994 Petitioner received a threatening letter direct from Respondent's attorney which letter endeavored to intimidate her into moving out of the marital home of the parties, prior to your Petitioner's even being served with the complaint in this matter. 18. Several years ago, your Petitioner awoke one night from a deep sleep to find Respondent hovering over her with his fist pointing at her face as if he was about to punch her. 19. By his conduct averred herein Respondent has used his physical, mental and emotional menace to place Petitioner in great fear for her life and in fear of imminent serious bodily injury. 20. Your Petitioner and her children are in immediate danger of further abuse and a court order is necessary to protect them. 21. For these reasons, Petitioner fears that if Notice is given to Respondent's attorney prior to the cntry of the Temporary Order, and if he informs Respondent of the action being Iaken, that this in itself could provoke violence in this matter. 22. Respondent is responsible to support Petitioner and the children of the parties and the partics narrowly avoided the power company turning off the lights just within the last week or so due to Respondent's having previously quit his jobs at Zembo Temple and Holiday Inn West. 23. Sometime in the next several days, Respondent may receive a settlement of $25,000. and his job back from the Army Depot which fund Petitioner believes should be protected by order of court to permit an equitable distribution of same. 24. Petitioner intends to file a Support Action for Spousal and Child Support and requests that this court add a temporary provision for IiUpport to the Protection From Abuse Order, ordering support in the amount of $300. per week. 25. Petitioner also requests temporary and permanent custody of the children of the parties pending an action for Custody which she intends to file in this matter, WHEREFORE Plaintiff seeks a temporary and final Order of Protection from Abuse prohibiting Respondent from having any contact whatsoever WiIh Petitioner, restraining Respondent from entering her place of employment, restraining Respondent from coming near her in the marital residence in Mechanicsburg or from harassing petitioner or the children in any way; Plaintiff further does pray for an order for temporary support and custody of the children of the parties and to set this matter for a hearing before the court within ten days, VERIFICATION OF PETITION BY PLAINTIFF I verify that the statements made in this Petition are true and correct. I understand that false statemenro herein are made subject to the penalties of 18 Pa. C.S. Sec. 4904, relating to unsworn falsification to authorities, ,/ .jd, J' Lrrh ,,t ~ ~ 4.C) PAULETIE LUCAS, PETITlONER DATED: /I J.a ) 91 I f DAVID S. BRADY, ESQ. PA. BAR II 35928 OLOE ENGLISH GAP 845 SIR THO!\lAS COURT HARRISBURG, PA. 17109 (717) 541-4400 FAX # 541-4401 , o t1 .C"'I ~ - '@ t ,i\, ~ ..,. en . ~t I~ , '.. ., ,~ I ~ N In 0') ':1: ,., 1:..;," tI-- . .r'l "':r ,..II.,;',~ . 'I, .~.. ~4 ~u ~ 1t Jl , , ," , " APH 5 1995~ .. ANN p, LUCAS PETITIONER IN 1HE COURT OF COMMON PLEAS CUMBERLAND COIJN1Y PENNSYLVANIA DOCKET NO. 94-6258 v. CHARLES A, LUCAS RESPONDENT PROTECl10N FROM ABUSE ACl10N TE~PORARY WIDER fO. P.~~~~':i~~ AND AND NOW, this ~ day of APRil.. 199" ,upon presentation and consideration of the within Petition, the Court enters the following Temporary Protection Order: 1. The Respondent shall forthwith remove himself from the marital residence of the panies pending hearing on the PlaintifPs Petition for Protection from Abuse. 2, Respondent shall refrain from abusing, harassing or threatening Petitioner physically, verbally, or by any form of menace wherever she may be. 3. Respondent is excluded from coming near Petitioner in the marital residence in which the panies reside during the pendency of this Order. 4, Respondent is prohibited from having contact with Petitioner, including, but not limited to, being restrained from entering the place of employment, business, or school of Petitioner, 5. Respondent is to surrender all t1rearms of any make or description whether such weapons are in or about the premises of the marital residence or at any other location in his possession or under his control, to the Hampden Township Police Depanment upon service of this Order. r . .. I' ..{ ( ..ll I f @ ,I lA ~;... .",".' \.",1. ~ "I' " IE rri ('Y) 'A:; '''' .'),.:, ,_. t "I '" ,,n "1\ .T ,.' /.'11 ':1 ' o~~' " Ji - " . APf( [) 1995Q...... , ANN P. LUCAS PETITIONER IN'I1rn COURT OF COMMON PLEAS CUMBERLAND COUNTI PENNSYLVANIA DOCKET NO. 94-6258 v. CHARLES A. LUCAS RESPONDENT PROTECI10N FROM ABLJSEACI10N l'EMPQJL\BY ORDER FOR PROI'ECI10N fROM ABUS~. AND TEMPORARY CUSTODY AND NOW, this 51h day of APRIL, 199'; . upon presentation and consideration of the within Petition, the Court enters the following Temporary Protection Order: 1. The Respondent shall forthwith remove himself from the marital residence of the parties pending hearing on the Plaintifrs Petition for Protection from Ahuse, 2. Respondent shall refrain from abusing. harassing or threatening Petitioner physically. verbally, or by any form of menace wherever she may be, 3. Respondent is excluded from coming near Petitioner in the marital residence in which the parties reside during the pendency of this Order. 4, Respondent is prohihited from having contact with Petitioner, including, but not limited to, being restrained from entering the place of employment, business, or school of Petitioner. , i , 5. Respondent i,~ to surrender all firearms of any make or description whether sudl weapons arc in or ahout the premises of the marital residcm:e or at any other I(Kation in his possession or under his control, to the I."'I',L.. ....r..~ t'~ I)",. mJlmlJRt upon ,'IVic f this Order. CV\#r,"".e.~C""" .r'" ~ A{A~"t- , \ I i 11 ~ t^~ \1. 1)1' ,I 'HtIW;r;,r.~ '~, IJ:; l ~' \,,11 t. h t' I;" ',I '; \ " . III 1\,,' : i ' ,', ..~ ", ,I lVR 1 9 3S ~~ 1~5 ,I " dl; - IE a ~ - >-,. "',. ", l.l,j ~-" . ',-, C':.r' 'r. - "'1 '..I .f. ::~ '1::. " I -OJ 1:""--":';", (.." II:,. , - ~ - =- SHERIFF'S RETURN CASE NOI 199~-06208 P CO""ONWEALTH OF PENNSYLVANIA. COUNTY OF CU"BERLAND KENNETH GOSSERT CU"BERLAND County, Pennsylvania, to law, says, that he .erved the , Sheriff or Deputy Sheriff of who being duly sworn acoording within ~O"PLAINT - DIVORCE the upon ~S ANN P defendant, at 1030.00 HOURS, on the -Z1h day of ADril 19~ at 4820 CHARLES ROAD "ECHANICSBURG, PA 17000 . CUUERLAND County, Pennsylvania, by handing to CHARLES A. LUCAS a true and atteated copy of the CO"PLAINT - DIVORCE and at the same time directing His attention to the contenta thereof. Sheriff's CoStSI Docketing Service Affidavit Surcharge 18.00 7.84 .00 .00 '2::1.84 So answers: ~ ,.~ /~~ ...,,'('~J.,.;,,:'/ . _ /..~ ' ,-r /P':":.' """,.,',01:. ~~ ~R~om8s Kli e, Sheriff 00/00/0000 by Sworn and subscribed to before me this ~__ day of ~ 19 91{ A. D. <..... J~" C': ttl...Ll<- A1N?J. Prothonot.r~ ,.