HomeMy WebLinkAbout95-00558
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SUZANNE K. WOODALL.
plaintiff
IN THE COURT OF COHMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
No. 95-557 civil Term
vs.
PROTECTION FROM ABUSE
ROBERT WOODALL. JR.
Defendant
PRAECIPE TO WITHDRAW ACTION
The olaintiff in the above-caotioned case reauests that
the TemDorarv Protective Order entered on Februarv 1. 1995. be
withdrawn. the order vacated and that no further leaal action be
oursued bv counsel.
To Lawrence E. Welker
prothonotary
1995
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J6an Carey, Attor ey for Plaintiff
./
No. 95-557
civil Term
Suzanne K. Woodall. Plaintiff
va.
Robert Woodall. Jr.. Defendant
P RAE C I P E
Filed
192.2.
Joan Carev. Attornev
LEGAL SERVICES. INC.
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 95-.157 CIVIL TERM
SUZANNE K. WOODALL,
Plaintiff
ROBERT WOODALL, JR.,
Defendant
PROTECTION FROM ABUSE
AND NOW,
TEMPORARY PROTECTION ORDER
this ~ day of February, 1995,
upon
presentation and consideration of the within Petition, and upon
finding that the plaintiff, SUZANNE K. WOODALL, now residing at
331 Cornman Road, Carlisle, Cumberland county, Pennsylvania, is
in immediate and present danger of abuse from the defendant,
ROBERT WOODALL, JR., the fOllowing Temporary Order is entered.
The defendant, ROBERT WOODALL, JR., DOB: 2/27/63, now
residing at 221 Walnut Street, Carlisle, Cumberland County,
pennsylvania, is hereby enjoined from physically abusing the
plaintiff, ROBERT WOODALL, JR., or placing her in fear of abuse.
The defendant is excluded from the plaintiff's residence
located at 331 Cornman Road, carlisle, Cumberland County,
Pennsylvania, a residence which is leased solely by the
plaintiff.
The defendant is ordered to refrain from contacting the
plaintiff at her place of employment.
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.
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The defendant is enjoined from removing, damaging,
destroying or selling any property owned jointly by the parties
or owned sOlely by the plaintiff.
A violation of this Order may subjeot the defendant to: i)
arrest under 23 Pa. C.s. 56113; ii) a private oriminal oomplaint
under 23 pa. c.s. 56113.1; iii) a oharge of indireot oriminal
oontempt under 23 Pa. C.S. 56114, punishable by imprisonment up
to six months and a fine of $100,00-$1,000.00; and iv) oivil
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 court order.
This Order shall remain in effect until modified or
terminated by the court after notice or hearing, A hearing shall
be held on this matter on the 6~v day of February, 1995, at
3:00 p.m., in Courtroom NO.~, Cumberland County courthouse,
Carlisle, Pennsylvania.
The plaintiff may proceed without pre-payment of fees
pending a further order after the hearing.
The Cumberland county Sheriff's Department shall attempt to
make service at the plaintiff's request and without pre-payment
of fees, but service may be accomplished under any applicable
rule of civil Procedure.
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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.
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The Pennsylvania state Police and the North Middleton 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 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
tho order. When that court is unavailable, the defendant shall
bo taken before the appropriate district justice. (23 P.S. S
6113) .
,
"
BY" the
.'
SUZANNE K. WOODALL,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
ii
CUMBERLAND COUNTY, PENNSYLVANIA
1
, ,
v.
NO. 95-
CIVIL TERM
ROBERT WOODALL, JR.,
Defendant
PROTECTION FROM ABUSE
NOTICE
You have been sued in court. If you wish to defend against the claims
set forth in the following pages, you must take action promptly after this
Petition, Order and Notice are served, by appearing personally or by attorney
at the hearing scheduled by the court and presenting to the Court your
defenses or objections to the claims set forth against you. You are warned
that if you fail to do so ths 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.
FEES AND COSTS
If the caee goes to hearing and the judge grants a Protection order, a
surcharge of $25.00 will be assessed against you. You may also be required to
pay attorney fees to Legal Services, Inc. for their representation of the
plaintiff.
, \
You ehould take thie paper to your lawyer at once.
If you do not have a
lawyer or cannot afford one, go to or telephone the office eet 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
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SUZANNE K. WOODALL,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 95-
CIVIL TERM
ROBERT WOODALL, JR.,
Defendant
PROTECTION FROM ABUSE
.
.
PETITION FOR PROTECTION ORDER
AND CUSTODY
RELIEF UNDER THE PROTECTION FROM ABUSE
ACT, 23 P.S, 5 6101 et seq.
A. ABUSE
1. The plaintiff, SUZANNE K. WOODALL, is an adult
individual residing at 331 Cornman Road, Carlisle, cumberland
County, Pennsylvania 17013.
2. The defendant, ROBERT WOODALL, JR., (DOB: 2/27/63), is
an adult individual residing at 221 Walnut street, Carlisle,
Cumberland County, Pennsylvania, 17013.
3. The defendant is the husband of the plaintiff.
4. Since approximately 12/93, the defendant has attempted
to cause and has intentionally, knowingly, or recklessly caused
bodily injury to the plaintiff, and has knowingly engaged in a
course of conduct or repeatedly committed acts toward the
plaintiff including following the plaintiff without proper
authorization, under circumstances which has placed the plaintiff
in reasonable fear of bodily injury. This has included, but is
not limited to, the fOllowing specific instances of abuse:
a. Since the defendant's release from prison in December
1994, the defendant has threatened the plaintiff on
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approximately a daily basis in ways including, but not
limited to, the following: that he has a gun and will use
it, saying he will cut her throat while she sleeps, and
threatening to beat her up until she knows who is boss;
these incidents cause the plaintiff to fear for her safety
because of the defendants past physical violence.
b. In or about December 1993, the defendant repeatedly
punched the plaintiff about the head and face with his
fists, causing the plaintiff to suffer two black eyes and
bruising to her forehead and arms. As a result of this
incident, the defendant was sent to prison for violating the
terms of his parole.
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 contacting the plaintiff at her place of employment.
7. The plaintiff desires that the defendant be enjoined
from harassing and stalking the plaintiff, and from harassing the
plaintiff's relatives.
8. The plaintiff desires that the defendant be restrained
from entering her place of employment.
9. The plaintiff desires that the defendant be enjoined
from removing, damaging, destroying or selling any property owned
jointly by the parties or owned solely by the plaintiff.
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B. EXCLUSIVE POSSESSION
10, The home from which the plaintiff is as~ing the court
to eXclude the defendant is rented in the name of the plaintiff
and the defendant has moved from the residence.
C. J\TTORNEY PEES
11. 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
from Abuse Act" of october 7, 1976, 23 P.s. S 6101 ~ seg,., 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. ordering the defendant to refrain from abusing the
plaintiff or placing her in fear of abuse;
2. ordering the defendant to refrain from contacting
the plaintiff at her place of employment.
3. ordering the defendant to refrain from harassing
and stal~ing the plaintiff and from harassing the
plaintiff'S relatives.
4. ordering the defendant to refrain from entering the
plaintiff's place of employment;
5, prohibiting the defendant from removing, damaging,
destroying or selling property jointlY owned by the parties
or owned solelY by the plaintiff;
6, Granting possession of the home located at 331
"
Cornman Road, Carlisle, Cumberland county, Pennsylvania, to
the plaintiff to the exclusion of the defendant pending a
final order in this matter;
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 year:
1. Ordering the defendant to refrain from abusing the
plaintiff or placing her in fear of abuse.
2. Ordering the defendant to refrain from contacting
the plaintiff at her place of employment.
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.
s. Prohibiting the defendant from removing, damaging,
destroying or selling property jointly owned by the parties
or owned solely by the plaintiff.
6. Granting possession of the home located at 331
Cornman Road, Carlisle, Cumberland county, Pennsylvania, to
the plaintiff to the exclusion of the defendant.
7. ordering the defendant to stay away from any
residence the plaintiff may in the future establish for
herself.
a. ordering the defendant to pay reasonable attorney
fees to Legal Services, Inc.
The plaintiff further asks that this Petition be filed and
served without payment of fees and costs by the plaintiff,
pending a further order at the hearing, and that certified copies
of this petition and order be delivered to the Pennsylvania State
police and the North Middleton police Departments who have
jurisdiction to enforce this Order.
The plaintiff prays for such other relief as may be just and
proper.
Respectfully submitted,
Joan \t ~e? ?t~laintiff
LEGAL SERVICES, INC.
a Irvine Row
carlisle, PA 17013
(717) 243-9400
The above-named plaintiff, Suzanne K. Woodall. verifies that
the statements made in the above petition are true and correct.
plaintiff understands that false statements herein are made
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,
subject to the penalties of 18 Pa. C.S, 64904. relating to
unsworn falsification to authorities.
Date:
f S)Al <
,
,
Suzanne K. ~bodall
VB
Robert Woodall, Jr.
In The Court of Cannon Pleas of
CUmberland County. Pennsylvania
No. 95-557 Civil Term
Tempor.ary Protection Order Protection
l'ran Abuse Notice and Petition for
Protection Order
~LTfI OF' PENNsvr.vANIA:
COONTV OF aJMBERLflND
R. Thanas Kline. Sheriff. who being duly sworn according to law. says
that he made diligent search and inquiry for the within named defendant. to wit:
Robert Wcxxlall. Jr.. but was unable to locate him in his bailiwick. He therefore
returns the within Temporary Protection Order Protection From Abuse Notic and Petition
For Protection Order as floor FOUND." as to the within named defendant. Robert
Woodall. Jr..
Sheriff's Costs:
Docketing
Service
18.00
2.80
20.80
So ,,".swers: f
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Sworn and Subscribed to Before Me
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This ....I..l.:::':: ~y of 7., (,,,, · , ;'
1995, ^,o.\tt'- O. IJuCCt... (,Q..t'~.
P 0 honotary ..
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As you know, the plaintiff has filed a legal action against you under the Protection Prom
Abuse Act and has obtalned a Temporary Protection Order. The plaintiff Is prepared to have
a hearing held In order to obtain a I1nal Protcc:tlon Order effective for one (I) year.
As nn alternntlve, you may consent to the entry DC the final Protection Order to be
In effect for one year. U you are "Wlnll to consent you should call Le&al Services, me, In
Carlisle at 243-9400, 766-8475 from the West Shore or 530.5866 from Shlppensbul'll, and
ask to speak to the staff person handllnll the case about a Consent AllI'ftIIIent.
The Consent Agreement should be prcp;ued before the time scheduled for the hearing so
the coun will know ahead of Urn" that the (,.l~ will not bo conlc5tcd. In some cases, regardless
of whether a settlement by Consent Agreement has been reached, the parties must appear In
court at the time scheduled for hearing. If the case Is unconlc5ted, the court appearance will be
brief. The judge will ma~.e sure the parties undentand the Consent Agreement and I1nal
protection Order.
If you do not agree to the entry of the I1na1 Protection Order, a contested hearing 'wlll
take place at the scheduled time. When a I1nal Protection Order Is entered, It will be sent or
given to you, the plaintiff, and the appropriate police departments. If you fall 10 abide by the
terms of the I1nal Protection Order you will be subject to Immediate anest, and a I1ne of
5100.00 to 51,000.00 and/or a jail sentence of up to six months and other relief.
FEFS AND COSTS
COURT ADMINISTRATOR, 4th FLOOR
CUMBERLAND COUNTY COURmOUSB
CARLISLE, PENNSYLVANIA 17013
TELEPHONE NUMBER: (717) 240.6200
If the case goes to hearing and the judge grants a Protcc:tlon Order, asurcharge of $25.00
will be assessed against you. You may also be required to pay attorney fees to Legal Services,
Inc. for their representation of the plaintiff.
YOU SHOULD TAKE mlS PAPER TO YOUR LAWYER AT ONCE. IF YOU
DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE
TIlE OFFICE SET FORm BELOW TO FIND OUT WHERE YOU CAN GET LEGAL
HELP.
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SUZANNE K. WOODALL,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
v.
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 95-557 CIVIL TERM
PROTECTION FROM ABUSE
ROBERT WOODALL, JR.,
Defendant
TEMPORARY PROTECTION ORDER
AND NOW, this ~ day of February, 1995, upon
presentation and consideration of the within Petition, and upon
finding that the plaintiff, SUZANNE K. WOODALL, now residing at
331 Cornman Road, CarliSle, Cumberland County, Pennsylvania, is
in immediate and present danger of abuse from the defendant,
ROBERT WOODALL, JR., the following Temporary Order is entered.
The defendant, ROBERT WOODALL, JR., DOB: 2/27/63, now
residing at 221 Walnut Street, Carlisle, Cumberland county,
Pennsylvania, is hereby enjoined from physically abusing the
plaintiff, ROBERT WOODALL, JR., or placing her in fear of abuse.
The defendant is excluded from the plaintiff's residence
located at 331 Cornman Road, Carlisle, Cumberland County,
Pennsylvania, a residence which is leased solely by the
plaintiff.
The defendant is ordered to refrain from contacting the
plaintiff at her place of employment.
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 jointly by the parties
or owned solely by the plaintiff,
A violation of this order may subject the defendant to: i)
arrest under 23 Pa. c.S. 56113; ii) a private criminal complaint
under 23 Pa. C.8. 56113,1; iii) a charge cf indirect criminal
contempt under 23 Pa. C.8. 56114, punisha~lo by imprisonment up
to six months and a fine of $100.00-$1,000.00; and iv) civil
contempt under 23 Pa. C.8. 56114.1. Resumption of co-residence
on the part of the plaintiff and defendant shall nct nullify the
provisions of the court order.
This Order shall remain in effect until modified or
terminated by the court after notice or hearing, A hearing shall
3~
. p.m.,
carlisle, Pennsylvania.
this matter 'on the
in Courtroom NO~,
~~ day of February, 1995, at
be held on
Cumberland County courthouse,
The plaintiff may proceed without pre-payment of fees
pending a further order after the hearing.
The Cumberland county Sheriff's Department shall attempt to
make service at the plaintiff's request and without pre-payment
of fees, 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 Pennsylvania state Police and the North Middleton 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 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 defendant shall
be taken before the appropriate district justice. (23 P.S. S
6113) .
By the Court,
1f~[tJ~ B. ~y17
TRUE COpy FROM RECOfl:.:>
In Testlmony whereof, I hero unto sol my hand
and the soal of said Court ~carliSle, Pa.
This /51' day 01 c7P J. , 109
0./:,' "t-'.
ProthonotalY
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SUZANNE K. WOODALL,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 95-
CIVIL TERM
ROBERT WOODALL, JR.,
Defendant
PROTECTION FROM ABUSE
NOTICE
You have been sued in court. If you wish to defend against the claims
sst forth in the following pages, you must take action promptly aftsr this
Petition, Order and Notice are servsd, by appearing personally or by attorney
at the hearing scheduled by the Court and presenting to the Court your
defensss or objections to the claims sst forth against you. You are warned
thst if you fail to do so the Court may procsed without you, and a judgment
may be entered against you by the court without further notice for any money
claimed in the Petition or for any other claim or relief requested by the
plaintiff. You may lose money or property or other rights important to you.
I'I!:ES AND COSTS
If the case goes to hearing and the judge grants a Protection Order, a
surcharge of $25.00 will be assessed against you. You may also be required to
pay attorney fees to Legal Services, Inc. for their representation of the
You ahould take thia paper to your lawyer at once. If you do not have a
lawyer or cannot afford one, go to or telephone the office aet forth below to
find out where you can get legal help.
COURT ADMINISTRATOR, 4th FLOOR
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PENNSYLVANIA 17013
TELEPHONE NUMBERt (717) 240-6200
plaintitt .
PETITION rOR PROTECTION ORDER
AND CUSTODY
RELlEr UNDER THE PROTBCTION rROM ABUSE
ACT, 23 P.B. S 6101 et seq.
A. ABUBE
1. The plaintiff, SUZANNE K. WOODALL, is an adult
individual residing at 331 Cornman Road, carlisle, cumberland
county, Pennsylvania 17013.
2. The defendant, ROBERT WOODALL, JR., (DOB: 2/27/63), is
an adult individual residing at 221 Walnut street, carlisle,
cumberland county, pennsylvania, 17013.
3. The defendant is the husband of the plaintiff.
4. since approximately 12/93, the defendant has attempted
to cause and has intentionally, knowingly, or recklessly caused
bodily injury to the plaintiff, and has knowingly engaged in a
course of conduct or repeatedly committed acts toward the
plaintiff including following the plaintiff without proper
authorization, under circumstances which has placed the plaintiff
in reasonable fear of bodily injury. This has included, but is
not limited to, the following specific instances of abuse:
a. Since the defendant's release from prison in December
1994, the defendant has threatened the plaintiff on
-.. ..----~..._...,.
approximately a daily basis in ways including, but not
limited to, the following: that he has a gun and will use
it, saying he will cut her throat while she sleeps, and
threatening to beat her up until she knows who is boss;
these incidents cause the plaintiff to fear for her safety
because of the defendants past physical violence.
b. In or about December 1993, the defendant repeatedly
punched the plaintiff about the head and face with his
fists, causing the plaintiff to suffer two black eyes and
bruising to her forehead and arms. As a result of this
incident, the defendant was sent to prison for violating the
terms of' his parole.
S. 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 contacting the plaintiff at her place of employment.
7, The plaintiff desires that the defendant be enjoined
from harassing and stalking the plaintiff, and from harassing the
plaintiff's relatives.
8, The plaintiff desires that the defendant be restrained
from entering her place of employment.
9. The plaintiff desires that the defendant be enjoined
from removing, damaging, destroying or selling any property owned
jointly by the parties or owned solely by the plaintiff.
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ll..... EXCLUSIVB POSSBSSION
10. The home from which the plaintiff is aSking the Court
to exclude the defendant is rented in the name of the plaintiff
and the defendant has moved from the residence.
C. ATTORNBY PEBS
11. 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
from Abuse Act" of October 7, 1976, 23 P.S. S 6101 n l1!N., 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. ordering the defendant to refrain from abusing the
plaintiff or placing her in fear of abuse;
2. ordering the defendant to refrain from. contacting
the plaintiff at her place of employment.
3. Ordering the defendant to refrain from harassing
and stalking the plaintiff and from harassing the
plaintiff's relatives.
4. Ordering the defendant to refrain from entering the
plaintiff's place of employment;
5. prohibiting the defendant from removing, damaging,
destroying or selling property jointly owned by the parties
or owned solely by the plaintiff;
6. Granting possession of the home located at 331
'.'1
Cornman Road, Carlisle, cumberland county, PennsYlvania, to
the plaintiff to the exclusion of the defendant pending a
final order in this matter;
7. Ordering the defendant to stay away from any
residence the plaintiff may in the future establish for
herself;
S. Schedule a hearing in accordance with the provisions of
the "protection from Abuse Act," and, after such hearing,
enter an order to be in effect for a period of one year:
1. Ordering the defendant to refrain from abusing the
plaintiff or placing her in fear of abuse.
2. ordering the defendant to refrain from contacting
the plaintiff at her place of employment.
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.
s. Prohibiting the defendant from removing, damaging,
destroying or selling property jointly owned by the parties
or owned solely by the plaintiff.
6. Granting possession of the home located at 331
cornman Road, Carlisle, Cumberland County, Pennsylvania, to
the plaintiff to the exclusion of the defendant.
7. ordering the defendant to stay away from any
residence the plaintiff may in the future establish for
herself.
s. Ordering the defendant to pay reasonable attorney
fees to Legal services, Inc.
The plaintiff further asks that this Petition be filed and
served without payment of fees and costs by the plaintiff,
pending a further order at the hearing, and that certified copies
of this Petition and Order be delivered to the Pennsylvania state
Police and the North Middleton Police Departments who have
jurisdiction to enforce this Order.
The plaintiff prays for such other relief as may be just and
proper,
Respectfully submitted,
~~o~
Joan arey, Atto ney r laintiff
LBGAL SERVICBS, INC.
S Irvine Row
Carlisle, PA 17013
(717) 243-9400
.
The above-named plaintiff, Suzanne K, Woodall, verifies that
the statements made in the above Petition are true and correct,
Plaintiff understands that false statements herein are made
subject to the penalties of 18 Pa. C.S. 64904, relating to
unsworn falsification to authorities.
Date:
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SUZANNE KATHRYN WOODALL,
Plainlill'
: IN TIlE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
vs.
: NO. 95-557 CIVIL TERM
ROBERT LEE WOODALL, II (Jr.),
Defendant
: PROTECTION FROM ABUSE
:NOTICE OF HEARING AND ORDER
YOU HAVE BEEN SUED IN COURT. If you wish to defend aguinst thcclaims set forth in thc following
papers, you must uppear atlhe hearing scheduled herein. If you fail to do so, the ease muy procecd against you und
a FINAL Order may be entered against you granting the relief requested in the Petition. In particular, you may be
evieted from yuur residence and lose other important rights.
;' J " ;, G)
A HEARING ON nlls MAlTER IS SCHEDULED ON MAY~~ ,1999, AT - .M.,
IN COURTROOM NO. ? OF THE CUMBERLAND COUNTY COURTHOUSE, CARLISLE,
-
PENNSYL VANIA.
You MUST obey the Ordcr that is uuaehed un1i1 it is modified or temlinated by the eourt ancr notiee and
hearing. If'you disobey this Order,lhe poliee muy arrest you. Violation of'this Order may subject you to a eharge
nfindirect criminal contempt which is punishuble by u line of up 10 $1,000.00 and/or up to six months injail under
23 Pu.C.S. *6114. Viol uti on may also subject you to prosecution and criminal penuhies under the Pennsylvania
Crimcs Cude. Undcr federal law, 18 U.S.C. *2265, this Order is enforceublc anywhere in thc United States, tribal
lands, U.S. Territories und 1hc Commonwealth ofPucrto Rico. If you travel outsidc of the statc and in1entionally
viulate this Ordcr, you may be subjec110 fedcral criminal proceedings under the Violenee Against Women Aet, 18
U.S.C. * 2261-2262.
You should take this paper to your luwyer at once, You have the rl~ht to have a lawyer represcnt you
at the hearing. The court will not, however, appoint a lawyer for you. If you do not have alawycr or cannot
afford one, go to or telephone the office set forth below to nnd out where you can get legal help. If you cannot
nnd a lawyer, you may have to proceed without one.
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE, CARLISLE. PENNSYLVANIA 17013
TELEI'IIONE NUM BER: (717)249-3166
AMERICANS WITllnISABILlTIES ACT OF 19911
The Court of Common l'lens ofCumherlnnd Count)' is required hy law to comply wilh the Americnns wilh Disnbililies Act
of 1990. For infonl1nlion nhoutnccessihle Iilcililies nnd rcnsonnblenecoml11odlllionsn\'ailnbletodisnhled individuals having
husiness helilre Ihe court, pleasc contnct our olTIce. AllnrrnngcmcllIs must hc 11111llc nllcnsl n hours prior to nny hcnring
or busincss bclilre the court, YOllmustnllend thc schcdulcd confercncc nr hcnring.
SUZANNE KATHRYN WOODALL,
PlaintiO.
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
vs.
: NO. 95-557 CIVIL TERM
ROBERT LEE WOODALL, II,
Defendant
: PROTECTION FROM ABUSE
TEMPORARY PROTECTION FROM ABUSE ORDER
Defendant's Name: ROBERT LEE WOODALL, II (JR.)
Defendan1's Dute of Birth: 02127/63
Defendant's Social St'curity Numbcr: 163-78-5865
Name of Protected Person: S~NNE KATHRYN WOODALL, Plaintiff
AND NOW, this 111 day of May, 1999, upon consideration ofth~ attached Petition for
Protection from Abuse,ikcourt hereby enters the following Temporary Order:
(8) I. Defendant shall not abuse, harass, stalk or threaten any ofthe above persons In
any place where they might be found.
(8) 2. Defendant Is evicted and excluded from the rcsldence at 507 A Hamilton Street,
Carlisle, Cumberland County, Pennsylvania, or any other permanent or temporary residence
where Plaintiff may live. Plalntlffls granted exclusive possession of the residence. Defendant
sball have no right or privilege to enter or he present on the premises.
(8) 3. Defendant Is prohibited from having ANY CONTACT with Plaintiff at any
location, Including, but not limited, to any contact at Plalntlfrs place of employment or the
residence ofber parents, Betty and Ray Rutter. Defendant Is speclnt'ally ordered to stay away
from the following locations for the duration of tbls Order:
Plalntlfrs place ofemplovment: McDonald's Restanrant, 1176 Harrlsbnrg Pike,
Carlisle, Cnmbcrland County, Pennsylvania.
Resldcnee of Plalntlfrs narents. Bettv and Ru\' Rutter: Sill Wagner DI'lve,
Carlisle, Cumherland County, Pennsylvania.
[29 4. Defendant shall not contact Plaintiff by telephone or by any other means,
Including through third persons.
[29 5. Pending the outcome of the final hearing In this matter. Plaintiff Is awarded
temporary custody of the followlnll minor child, isaiah Robert Lee Woodall, I year old:
Until the final hearing, all contact between Defendant and the child shall be
limited to the following: No contact.
The local law enforcement agency In the jurisdiction where the child Is located
shall ensure that the child Is placed In the care and control of PlaIntiff In
accordance with the terms of this Order.
[29 6. Defendant shall Immediately relinquish the followlnll weapons to the Sherlfrs
Office or a designated local law enforcement agency for the delivery to the Sherlfrs Office:
any and all guns and/or knives he may possess. Defendant Is prohibited from possessIng,
transferring or acquiring any other weapons for the duration of this Order.
rx'
LC/ 7.
The following additional relief Is granted:
The Cumbcrland County Sherlfrs Department shall attempt to make scrvlce at
Plalntlfrs request and without pre-payment of fees, but servlcc may be
accomplished under any applicable Rule of Civil Procedure.
This Order shall be doekcted In the office of the Prothonotary and fonvarded
to the Sherlfffor service. The Prothonotary shall not send a copy orthls Order
to Defendant by mail.
This Ordcr shall remain In effect until modified or terminated by the Court and
can be extended beyond Its or11llnal expiration date If the Court finds that
Defendant has committed an net of abuse or has engaged In a pattern or
practice that Indlcatcs risk of harm to Plaintiff.
Defendant Is enjoined from damalllng or destroylnll any property owned jointly
by the parties or own cd by Plaintiff.
Defendant Is to refrain from harasslnll Plalntlfrs relatives.
[29 8. Ccrtlfied copies of this Order shall be provldcd to thc pollee dcpartments where
Plaintiff resides and any othcr allcncles specified hereafter: Carllslc, North Middleton
Township, und Middlesex Township Pollee Departments.
(8) 9.
TillS ORDER SUPERSEDES
Ii9 ANY PRIOR PFA ORDER and
Ii9 ANY PRIOR ORDER RELATING TO CIIILD CUSTODY
TillS ORDER APPLIES IMMEDIA TEL YTO DEFENDANT AND SHALL REMAIN
IN EFFECT UNTIL MODIFIED OR TERMINATED BY THIS COURT AFTER NOTICE
AND IIEARING.
NOTICE TO DEFENDANT
Defendant Is hereby notified that violation of this Order may result In arrest for
Indirect criminal contempt, which Is punishable by a fine of up to $1,OOll.Oll and/or up to six
months In jail. 23 Pa.C.S. ~6114. Consent of the Plaintiff to Defendant's return to the
residence shall not Invalidate this Order, which can only be changed or modified through the
filing of appropriate court papers for that purpose. 23 Pa.C.S. ~6113. Defendant Is further
notified that violation ofthls Order may subject him/her to state charges and penalties under
the Pennsylvania Crimes Code and to federal charges and penalties under the Violence Against
Women Act, 18 U,S.C. ~!i 2261-2262. Any protection order granted by a court may be
considered In any subsequent proceedlngs,lnc1udlng child custody proceedings, under title 23
(Domestic Relations) of the Pennsylvania Consolidated Statutes.
NOTICE TO LAW ENFORCEMENT OFFICIALS
This Order shall be enforced by the pollee who have jurisdiction over Plaintiffs
residence OR any locations where a violation of this order occurs OR where Defendant may
he located. If Defendant violates Paragraphs I through 6 of this Order, Defendant may be
arrested on the charge of Indirect Criminal Contempt. An arrest for vlolutlon of this Order
may be made without warrunt, based solely on probable euuse, whether or uot the violation
Is committed In the presence of luw enforcement.
Subsequent to un arrest, the luw enforcement officer shall seize all weupons used or
threatened to be used during the violation of this Order OR during prior Incidents of abuse.
Weapons Illust forthwith be dellvcred to the Sheriffs office of the county which Issucd this
Order, which ofllce shall mallltuln posscsslon of the weapons until further Order of this Court,
unless the weapon/s are evidence of a crime, In which case, they shall remain with the laW
enforcemcnt agcncy whose officer made the arrest.
Judge
Joan Carey
LEGAL SERVICES, INC.
Attorney for P\uintitl'
SUZANNE KAT1IRYN WOODALL,
Plnintiff
: IN TI IE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
vs.
: NO. 95-557 CIVIL TERM
ROBERT LEE WOODALL, II (Jr.),
Dcfcndnnt
: PROTECTION FROM ABUSE
PETITION-FOR
PROTECTION FROM ABUSE
I. Thc Plnintiffis Suznnnc Knlhryn Woodnll.
2. The nnme ofthc pcrson who sccks protcction from ubuse is Suznnne Knthryn Woodnll.
3. Pluintifl's addrcss is 507A IInmilton Slrcel, Carlislc, Cumberland Counly, Pcnnsylvnnin
17013. Plnintiff is tcmporarily residing nt her pnrcnts' home locnlcd nl 50 I Wagncr Drive, Cnrlisle,
Cumbcrlnnd County, Pennsylvnnia 17013.
4. Dcfcndnnt is currently residing at 221 Wnlnut Slreet, Cnrlisle, Cumberlnnd County,
Pcnnsylvania 17013, which is thc homc of his pnrents, Churlcnn nnd Robert Woodall.
Defcndnnt's Socinl Sccurity Numbcr is 163-78-5865.
Defcndant's dnte of birth is 2/27/63.
To the bcst of Pin in till's knowlcdge, Dcfcndant is uncmploycd,
5.
Dcfcndnnt is Plnintill's husbnnd nnd thc lillhcr ofthc purtics' I ycnr-old child.
6.
Abusc:
Plnintiffnnd Dcfcndnnt hnvebccn involvcd in the following court aClion for Protcction From
Cuscnume
Woodnll v. Woodnll
ClIse No.
95-557
Dutc IiIcd
Februllry I, 1995
Court of Common Plclls
Cumbcrland County
7. Dcfcndul1l wusarrcstcd byCurlislc Police on or about May 5, 1999, nnd chargcd with simple
nssnull as u rcsull ofthe incident dcscribcd in paragraph II involving PlainlilT. Defcndant was rclcascd on
his own rccognizuncc on or ubout Muy 5, 1999, allcr bclng nrrnigncd bclllre Districl Justicc Corren!. A
prcliminary hCtlring in the cnsc is schcdulcd to bc hcard by District Justice Corrcal on July 28, 1999, nt 3:30
p.m.
In uddilion,thc following criminnl court dockctnumbcrs urc listcd in thc Cumbcrlnnd County Clcrk
ofCourt'sOflicc (88-1790; 92-1145; 92-51804: 93-2J22: 95-IJ89; 96.1508; 96-1509; 96-1510; 96-01511,
und 97-51(3) rcfcrcncing Dcrcndul1l's convictions in Cumhcrlnnd Cllunty Illr crimcs ineluding. but not
Iimitcd 10, drug.relulcd offcnscs, uggrnvutcd ussnull (F-I ),ullll stutc und county-lcl'e1 pnrule und probntion
rcvocations. County criminal rccords ulso indicale thai Defcndunt wus convictcd of Fcdernl crimcs.
Defendant was reccntly released from Statc supervised parole.
8. Plaintiffsccks tcmporary cuslody oflhe Ibllowing ehild:
Name
Isaiah Robcrt Lcc Woodall
Addrcss
507A Hamilton Slrcet
Carlisle, I'A
Rirthdatc
May 3, 1998
9. Plaimill' and Defendant lire thc parents of the following minor child:
Name
Isaiuh Robert Lec Woodall
~
I year old
10,
custody:
Thc following infornllltion is provided in support of Plaint ill's rcqucsl for an Order of child
a) Thc child was not born out of wedlock.
b) The child is prcsently in the cuslody of Plaintiff, Suzanne Kathryn Woodall, who
is Icmporarily residing with herpurenls at their home located ut50 I Wagncr Drive, Carlisle,
Cumberland County, Pennsylvunia. Pluintifrs pcrmancnt address is 507A Hamillon Street,
Cllrlisle, Cumberland County, Pennsylvania.
c) Sincc his birth,lhcchild has rcsided with the following pcrsons and at the following
uddresscs:
Pcrsons ehild Iivcd with Address When
Pluintiff, IInd her purcnts, 501 Wugncr Drive From May 5, 1999
Dctty und Ruy Ruttcr Curlisle, PA to the prescnt
Plaintiff und Dcfcndlllll S07A lIamillon Strcct From February 16, 1999
Carlislc, PA to Muy 5, 1999
PIa inti ff 507A Hamilton Strcct From Septcmbcr 1998
Curlislc, PA to Fcbruary 16, 1999
Plaintifi' and Defcndanl 507 A Hamillon Slrecl From May 3, 1998
Carlislc, PA to August 1998
d) Plaintiff, thc mothcr ofthc child, is SUZ1ll1l1e Kathryn Woodall, who is tcmpomrily
residing alSO I Wagner Drivc, Carlislc, Cumbcrland Counly, Pcnnsylvanill.
c) Shc is mllrricd.
I) I'lninlilTcurrcntly rcsidcs with thc following pcrsons:
Nnmc
Isninh Robcrt l.cc Woodnll
Ilctty nnd Rny Ruttcr
Rclntionshil1
hcr son
hcr pnrcnts
g) Dcfendnnt,thc fnthcr ofthe child, is Robert Lcc Woodnll,ll (Jr.), currcntlyrcsiding
Ilt 221 Wlllnut Strccl, Cnrlisle, Cumbcrlnnd County, I'cnnsylvnnill.
h) lie is mnrricd.
i) Defcndnnt currcnlly resides with thc following pcrsons.
Nnme
Chari can Ilnd Robert Woodnll
l.ec nnd Tamrn Woodall
Aliynh Woodllll
Relntionshio
his parcnts
his brothcr nnd sister-in-lllw
his neicc
j) I'lnintiffhas not prcviously pllrticiplltcd in any Iitiglllion concerning custody of the
above mcntioncd child in this or nny other Court.
k) I'lnintiff has no knowlcdge of any custody procccdings concerning this child
pcnding beforc Il court in this or Ilny othcr jurisdiction.
\) I'lninllff docs not know Ilny pcrson not a party to Ihis action who has physiclll
custody ofthe child or c1nims 10 hnve cuslody or visitation rights with respect to the child.
Ill) The best intcresls and pcnnnnentwelliue of the minor child will be met if custody
is tcmporllrily grnntcd to I'lllintiffpending a hearing in this mntter for rCllsons including:
I) I'lllintiff is Il rcsponsible parent who hils providcd for the cmotionlll and
physiclll necds of the child since his birth, nnd who clln best take care ofthc minor
child.
2) Dcfcndnnt hns shown by his abusc ofl'lninliffthnt he is notnn approprintc
role modcl for the minor child.
11. The fllcts of thc most rcccnt incidcnt of abuse arc ns li,lIows:
Approxinlllle Dllte:
Approximate Timc:
I'lnce:
On or nbout Mny 5, 1999
6:00 n.m.
S07A IInmillon Strcct, Cllrlislc. Cumberlnnd County,
I'cnnsylvnnin, I'lllinlilfs rcsidcncc.
On or nbout Mny S, 1999. Iltllpproximalcly 6:(l0 n.m., Dcfcndllnl climbcd
on lop ofl'lninlilTns shc lay in bcd. nllllthrcntcncd Ihal he was going 10 \cnve and
tnkc Ihcir I-ycnr-old bab)', Isaiah. bUltllllt shc would not knoll' bcclluse shc would
not hc armmd. Allcr ()cfcllllanl fcll aslccp n short limc later, I'lnintlff snw a
, ,
scrrutcd stcuk knifc sticking out of his pnnts pockct, nlllllcuring thnt hc mcnntlo
slnb hcr with ii, shc rCll10ved thc knife nnd put it nwny in Ihc kitchcn, Whcn
Dcfcndnnl awokc, he punched Plnintiff rcpcnledly nbout hcr hcnd IInd lilcc with
bOlh his lists, knocking hcroffol'thc bcd, pullcd hcr hnir, grubbcd forthc knilc,lInd
Iinding it wns gone,lhrcntcncd Plnintiffshouting, "I'm going lotllkc cnrcofyou."
Fcuring for hcr Iifc, 1'lninlilT nmto Ihe door. Delcndunt lilllowcd l'lnintiff nnd
pushcd his hund ngninstthe door to kccp her from gClling out, but she wns ablc to
gctoulthc door IInd onto the porch bcfore he grubbcd her. As Plnintiff screnll1cd
for hclp and hcld onto thc porch rniling, Defcllllnnt wrnppcd his ann mound hcr
ncck inn chokc hold, grnbbed hcr nbout her torso with his olhcr ann, und tricd to
pull hcr bnck inside thc hOllsc. Whcnuucighbor who hcnrd Plaintifl's scrcnms,
ycllcd tllllt shc had cnllcd thc policc, Dclcndantlcl go ofl'lainliffbuttricd 10 cocree
hcr not to liIe chnrgcs agninst him. Carli sic Police arrcstcd Dcrcndantnnd chnrgcd
him with simple assnull. Plainliffsustaincd bruising IIbout hcr eyc, swelling nnd
sorcncss IIboul hcr rncc nnd hcnd, a bloodicd nose, allll hClldnches liS a rcsult ol'this
incidcnt. Dclcndant WIlS nrruigncd beforc District Justicc Corrclll und relcascd on
his own rccognizancc. A prcliminary hcaring in Ihc CIlSC is schcdulcd bcforc
District Justicc Corrclll on July 28,1999, at 3:30 p.m.
12. Dclcndant has commillcd thc following prior acts of abuse against Plaintin:
,
a) In or lIboutlale April 1999, in the carly hours of the morning, Defendant
came home, woke Plainlirf from her slecp, stood at her side of the bed holding a
knife he pointcd at hcr, and yell cd at her making false accusations. Fearing that
Delcndanl was going to kill hcr, Plnintifflalkcd to him. trying to cahn and reassure
him for approximlltcly two hours bcfore hc putthc knifc downllnd went to slccp.
Later the same day, in thc evening, Dclcndant thrcutcned Plaintiff during
anllrgumcnt suying, "I spared your Iilc twicc: Ihc ncxt timc I willlinish it."
b) In or aboutlntc Mareh 1999, Delcndanltold Plaintifi'thnt hc bought a gun
with his paychcck, and thrcatcncd to kill hcr if hc found thnt shc had bcen with
SOllll.~lIlC else.
c) In or aboutlntc Fcbruary 1999, PlnintifTnwoketo Iind Defcndant sillingon
thc cdgc or the bcd holding n knifc in his hnnd. Dcfcndant threatcncd to kill
Plnintiffsnying hc could not trust hcr,nnd that shc wns unfnilhfulto him. J'lainliff
tnlkcd to Dclcndnnt and rcnssurcd him unlil hc put the kni fc down. Defcndant had
just bccn rclcllscd from Cumbcrlnnd County Prison on Fcbrunry 16, 1999, nOcr
scrving n six monlh scnlcnce IiII' violntionof his Stntc Pnrole conditions.
d) Inoraboul summcr 1998, Dcfcndnnt bccomcnngrywhcn Plnintiff, whohnd
givcn birth to thcir bnby in MlIY 1998. rcruscd to hllvc scx with him. D,'lcndnnt
gmbbcd hcr ncck wilh both his hnnds, chokcd hcr despitc hcr rcpcatcd plcns liJrhim
to slOp, lInd whcn shc could nolongcr brcnthc, ICllring IlliIt hc wns killing hcr, hc
nbruptly Ict goofhcr,
c) Plninlifflilcd nPctition for Prolcction From Abuse ngainst Dcfcndnnt nlthc
nbovc.listcd dockct numbcr on Fcbnlluy I, 1995. Dcfcndnnt was ncver scrvcd wilh
Ihc Tcmpornry Protcction Ordcr bcforc thc nclion was withdrawn on Fcbrunry 7,
1995. nlPlnilllil'l's rcqucst.
Sincc lIpproximnlely Dcccmbcr 1993, Dcfcndnnt hns abuscd PllIintilT in
wnys including. blltnot limitcd to, shoving. grnbbing, slllpping, punching, kicking,
choking, pulling hcr hllir, intimidnling her, Ihrcatcning to bcnl hcr until shc knows
who is boss, nnd thrcntcning to kill hcr by cUlling hcr thrallt whilc shc slccps. In
Dccembcr 199J, Dclcndllnt bcatPllIintiffwith his lists rcpcnlcdly lIbout hcr hcnd,
lilCC, lInd nnns. Plainliff sustllincd bruising 1I11l1 swclling nhout hcr cycs lInd lilCC,
nnd bruisingllboul hcrllmlS nnd sought mediclll trcnlmcnt forhcrinjurics liS II rcsull'
of this incidcnt. Dcfcndnnt, who WllS on parolc at Ihc timc, wns lIITcstcd, his pllrolc
rcvokcd for viollltion ofpnrolc conditions relnting to this incldenl, lInd servcd timc
in prison liS II rcsult.
13. Dclcndllnt hils used or thrcatencd to use the following wellpons lIgainstPllIintilT: guns lInd
knivcs.
14. Thc following police dcpllrtmcnls or 11Iwenforccmcnt agencies in the arcll in which Plainliff
lives should bc providcd with II copy ofthc Prolcction Ordcr: ClIrlisle Policc Dcpllrtmcnt. North Middlcton
Township Policc Dcpllrtmcnt, and Middlescx Township Policc Dcpartmcnl.
15. Therc is an immcdiatc lInd prescnt dangcr of further abusc IrUln Defcndllnt.
16. PllIinliff is lIsking the Court to cvictllnd cxclude Dcfcndllnt fromthc rcsidcncc lit 507A
IInmilton Strect, Cnrlislc, Cumbcrlllnd County, I'cnnsylvllnin, which is Icascd in PllIintifl's nil me only.
WIIEIU:FORE, I'I.AIN1'IFF REQUESTS 1'IIA1' TilE COURT EN1'Elt A TEMPORARY
ORnER, ANn AI~rER IIEARING, A FINAl, ORnER 1'IIA1' WOUl.n no TilE FOl.l.OWING:
A. Rcslrnin Delcndant from nbusing, Ihrclllcning, harnssing, or stlllking
Plnintiffin any plllce whcrc PlaintiffmllY bc found.
D. Evict lInd exclude Dcfcndllnt from PllIintifl's residcncc nnd prohibil
Dcfcndllnt fromllllcmpting to enter lIny tcmpornry or pcnnllncnt rcsidencc ofthc
PllIinliff.
C. AWllrd Plaintiff tcmpornry custody of the minor child nnd plllce the
following rcstrictions or contacl betwecn Dcfcndanlnnd chi Id: No contact pcnding
further Ordcr 1I1lcr thc hCllring schcdulcd in this mnllcr.
D. Prohibit Dcfcndnnt Irom havingnnycontllctwith Plainliffllllll/orhcrminor
child, cithcr in pcrson. by Ielcphonc, or in writing, pcrsonnlly or through Ihird
pcrsons. including. but not limitcd to. nny contnct lit Plaintill's placc of
cmploymcnt, thc dny cnrc lilcility ofhcr minor child. or Ihc rcsidcncc ofPllIintifl's
pnrcnts.
E. Prohihit Dclcndnnt frum hnving nny contncl with Plnintill's relativcs and
Plnintill's child Iistcd inlhis Pelition.
r. Ordcr Dclcndnnt 10 tcmporurily tum over wcnpons to thc Shcrin' of this
County nnd prohihit Dcfcndnnt from trunsferring, acquiring or possessing nny such
wcnpons for thc durution ofthc Ordcr.
G. Dircct Dcfcndnnt 10 pny Plnintiff for the rcnsonnblc linnncinl losses
suffered ns a rcsult of the nbusc,to he dctemlined at thc hcnring.
II. Ordcr Dcfcndnntto pny thecosls ofthis nelion, including liIingnnd scrvice
fecs.
I, Order Dcfendnnt to rcimburse Cumberlnnd County, a Legnl Services
funding source, $250.00 for the vnlue of the Icgnl scrviccs provided to Plaintiff for
the cost oflitignting this cnse ifthc case goes to hcaring.
J. Ordcr the following ndditionnl relief, not listed nbove:
I} Defcndant is rcquired to relinquish to the sheriff any lirenml
license Defendnnt mny possess. Dcfendnnt's wcnpons and lireannlicense
mny be rctumcd at the cxpinltion of the Protection Ordcr aileI' Defendant
has submittcd n writtcn rcqucst to the Court for the rclum of the wcapons
and the Court hns notilicd Plnintiff of the requcsland givcn Plnintiff an
opportunity to rcspond.
2} Dcfcndnnt is cnjoined from damaging or dcstroying any propcrty
owned jointly by the pnrtics or owncd by Plnintiff.
3} Defendant is to rcfruin from harussing Plaintifrs relatives or the
minor child.
K. Grunt such othcr relicf as the court dcems approprintc.
L. Ordcr the police or othcr Inw enforeemcnt agency to serve Dcfendant with
n copy ofthis Pctition,any Order issued, and the Order for J Icaring. Petitioner will
infonn the dcsignntcd nuthority of any addrcsses, othcr than Dcfendnnl's residence,
whcre Dclcndant can be scrvcd.
Dale:
.Ii - / 7 - '/1
. .
Rcspcctfully suhmitted, /
Jk{l.,J @/{}(" (, 1//
''Jonn Cnrcy, Altomcy I'M I'lnintin'
1.EGA1. SERVICES, INC.
H Irvine Row
Cnrlisle, I' A 17013
(717) 243.1)40ll
VERIFICATION
Suzu n' Kathryn Wood 11, Pluin1ill'
I verify thut I om the Petitioner as dcsignated in the present action und thut the Iilets IInd
statements contllined in the ubove Petition ure true IInd correct to the bes10f illY knowledge. I
understllnd thutllny tillse statements lire Illllde suhjeetto the penulties of 18 Pu.C.S. *4904, relating
to unswom lillsilieu1ion to lIuthorities.
Dated:
6.))..Qq
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ROBERT LEE WOODALL, 11 (Jr.),
Defendant
: PROTECTION FROM ABUSE
vs.
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 95-557 CIVIL TERM
SUZANNE KATHRYN WOODALL,
PllIintilT
FINAL PROTECTION ORDER
Defcndant's Name: ROBERT LEE WOODALL, \I (JR.)
Defendant's Datc of Birth: 02/27/63
Defendant's Social Security Number: 163-78-5865
Name of protected Persons: SUZANNE KATHRYN WOODALL
AND NOW, this '1"61/;-, day of May, 1999, the eourt havlngjurlsdletlon
over the parties and the subject-matter, It is ORDERED, ADJUDGED, and
DECREED as follows:
Plaintiff, Suzanne Kathryn Woodall, Is rcpresentcd by Joan Carcy of Legal Scrvlces, Inc.;
Defendant, Robcrt Lee Woodall, II (Jr.), Is unrepresented, but has been advised of his right to
counsel In this mattcr.
Dcfendant, although agreeing to thc terms of this Order, does not admit the allegations
made In the Petition.
I&> Plalntlfrs rcquest for a Final Protection Order Is granted pursuant to the consent of
Plaintiff.
o p!aintift's request for a Final Protection Order is denied
I&> 1. Defcndant shall not abusc, stalk, harass, thrcaten Plaintiff or any othcr
protected person In any place where they might be found.
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I&> 2, Defcndant Is completely evicted and cxcluded from thc residence at 507A
lIamllton Street, Carlisle, Cumbcrland County, Pennsylvllllla, or any other resldcnce whcre
Plaintiff may live. Exeluslve possession ofthe residence Is grunted to Plaintiff, Defendant shall
have no right or privilege to enter or be present on the premises.
[J On _ at_.m., Defendunt I11UY en1er the residence to retrieve his/her clothing und
other personal elTects, provided that Dclcndunt is in the eOl11puny of u luw enforeement
otlicer when such retrieval is mude.
(8) 3. Defendant Is prohibited from having ANY CONTACT with the Plaintiff at any
location, Including, but not limited to, any contact at the Plalntlfrs place of employment, her
parents' residence, and/or the day care facility of her minor child. Defendant is specifically
ordered to stay away from the following locations for the duration of this Order:
Plalntlfrs place ofemplovment: McDonald's Restaurant, I 176 Harrisburg Pike,
Carlisle, Cumberland County, Pennsylvania.
Residence of PlalntlWs parents: SOl Wagner Drive, Carlisle, Cnmberland
County, Pennsylvania.
(8) 4. Defendant shall not contact the Plaintiff by telephone or by any other means,
Including third parties.
"
(8) 5. Custody of the minor child, isaiah Robert Lee Woodall, shall be as follows:
Plaintiff shall have primary physical and legal custody of the child pending further Order of
Court. (see attached Custody Order).
(8) 6, Defendant shall Immediately turn ovcr to the Sherlfrs Office, or to a local law
enforcement agency for delivery to the Sherlfrs Office, the following weapons used or
threatened to be used by Defendant In an act of abuse against Plaintiff and/or the minor
chlld/ren:
(8) 7. Defcndant Is prohibited from possessing, transferring or acquiring any other
weapons for the duration of this Order. Any weapons delivered to the sheriff under
Paragraph 6 of this Order or under Paragraph 6 of the Temporary Order shall not be
returned until further Order of Court.
(8) 8.
The following additional relief Is granted as authorlzcd by ~61 08 of this Act:
This Order shall remain In effect until modified or terminated by the Court and
can he extcnded heyond Its original explrutlon dute If the Court finds that
Defcndant has committed an act of abuse or has en~a~ed In a pattcrn or
practice that Indicates risk of harm to Plaintiff.
Defendant Is rcqulred to relinquish to the sheriff any firearm license the
defendant may possess, The Defcndant's weapons and firearm license may be
returned at the expiration of the Protection Order after the defendant has
submlttcd a written rcqucst to the Court for the return of the weapons and the
Court has notified Plaintiff of the re1luest and given Plaintiff an opportunity to
respond. A copy of this Order shall be transmitted to the chief or head of the
police department of (wherc the defendant resides) and the sheriff of
Cumberland County.
Defendant Is enjoined from damaging or destroying any property ownedjolntly
by the parties or own cd solcly by Plaintiff,
Defendant Is to refrain from hurasslng Plalntlfrs relatives or the minor child.
o 9. Defendant is directed to pay temporary support for _ as follows: _' This Order for
support shall remain in effect until a final support order is entcred by this Court. However, this
Order shall lapse automatieally ifPlaintilrdoes not file a complaint for support with the Court within
fifteen (15) days ofthe date of this Order. The amount ofthis temporary order docs not neeessarily
renect Defendant's correct support obligation, whieh shall be detennined in accordance with the
guidelines at the support hearing. Any adjustments in the final amount of support shall be credited,
re1roactive to this date, to the appropriate party.
o 10. The eosts of this action arc waived as to Plaintiff and imposed on Defendant.
o 11. Defendant shall pay $_to Plaintiffnscompensation for Plaintill's out-ol:pocketlosses,
which are as follows: OR
o Plain1iffis granted leave to present a pC1ition, with appropriate notiee to Defendant,
to _ requesting recovery of out-of-pocket losses. The peti1ion shall include an exhibit
itemizing all claimed out-of-pocket losses, copies of all bills and estimates of repair, and an
Order scheduling a hearing. No fee shall be required by the Pro1honotury's ollice for the
filing oflhis petition.
o
12.
BRADY INDICATOR
o I. The Plaintill" or protected personls is a spouse, fanner spouse, a person who
eohabitates or has eohubited with Delendant, a parent of II eOl11l11on child, a child of that
person. or a child of Delendunt.
o 2. This Order is being entered afierahearing ofwhieh Delendnnt received netunl
notice und hud un opportunity to be heurd.
o 3. Paragraph I of this Ordcr has been checked to restrain Delendunt fhlJn
harassing, stulking, or threatening Plaintiffor protected person/so
o 4. Dcfendant rcpresents a eredible thrcatto thc physienl sule1y of Pluin1iff or
other pro1ected person/s OR
o Thc tcnns of this Order prohibit Defendant from using, uuempting to use, or
thrca1ening to use physieallbree against PlaintilTor protectcd person lhnt would rensonably
be expected to cause bodily injury.
I:B> 13. THIS ORDER SUPERCEDES ANY PRIOR PFA ORDER and ANY PRIOR
ORDER RELATING TO CHILD CUSTODY.
I:B> 14. All provisions of this Ordcr shall expire one year from the date this Order Is
entcred.
~OTICE TO THE DEFENDANT
VIOLATION OF THIS ORDER MAY RESULT IN YOUR ARREST ON THE
CHARGE OF INDIRECT CRIMINAL CONTEMPT WIIICH IS PUNISHABLE BY A FINE
OF UP TO 51,000 AND/OR A JAIL SENTENCE OF UP TO SIX MONTHS. 23 PA.C.S.
fi6114. VIOLATION MAY ALSO SUBJECT YOU TO PROSECUTION AND CRIMINAL
PENALTIES UNDER THE PENNSYLVANIA CRIMES CODE. THIS ORDER IS
ENFORCEABLE IN ALL FIFTY (50) STATES, TilE DISTRICT OF COLUMBIA, TRIBAL
LANDS, U,S. TERRITORIES, AND TilE COMMONWEALTH OF PUERTO RICO UNDER
THE VIOLENCE AGAINST WOMEN ACTION, 18 U.S.C. ~2265. IF YOU TRAVEL
OUTSIDE OFTHE STATE AND INTENTIONALLY VIOLATE THIS ORDER, YOU MAY
BE SUBJECTTO FEDERAL CRIMINAL PROCEEDINGS UNDER THAT ACT. 18 U.S.C,
~~ 2261-2262. IF PARAGRAPH 12 OFTHIS ORDER HAS BEEN CHECKED, YOU MAY
BE SUBJECT TO FEDERAL PROSECUTION AND PENALTIES UNDER THE "BRADY"
PROVISIONS OFTHE GUN CONTROL ACTION, 18 U.S.C. ~922(G), FOR POSSESSION,
TRANSPORT OR RECEIPT OF FIREARMS OR AMMUNITION.
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NOTICE TO LAW ENFORCEMENT OFFICIALS
The pollee who havc jurisdiction over Plalntlrrs resldencc OR any location where a
vlolutlon of this Order occurs OR where Defendant may be located, shall enforce this Order.
An arrest for violation ofPara"raphs I throu"h 7 orthls Order may be without wRrrant, based
solely on probablc causc, whcthcr or not the violation Is eommltled In the prescnce of the
police. 23 Pa.C,S. ~6113.
Subsequent to an arrest, thc pollee officer shall selzc all weapons used or threatened to
be used during thc violation of the Protection Order or during prior Incidents of abuse. The
Cumbcrland County Shcrlfrs Department shall maintain possession of the wcapons until
further Order of this Court. When Defendant Is placed under arrest for violation of the
Order, Defendant shall be taken to thc appropriate authority or authorities beforc whom
Defendant Is to be arraigned. A "Complaint for Indirect Criminal Contempt" shall then be
completed and signed by the pollec officer OR Plaintiff, Plalntlfrs presencc and signature are
not required to file the complaint,
If sufficlcnt grounds for violation of this Order are alleged, Defendant shall bc
arraigned, bond set and both partlcs glvcn notice of the datc of the hearing.
Date:~hl 2..:X 199)
I
BY THE COURT,
/) !lLr1ld~ ~ r
V . Geor~..E? Hoffer, President Judge
This Order is entered pursuant to the consent of Plaintiff and Defendant:
c~
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Robert Lee Woodall, (( (Jr.), Defendant
Suzann'
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Joltn Carey, Allome or Plaintifl'
LEGAL SERVICES, INC.
8 Irvine Row
Carlisle, P A 17013
(717) 243-9400
SUZANNE KATHRYN WOODALL,
Plaintill'
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
vs.
: NO. 95-557 CIVIL TERM
ROBERT LEE WOODALL, II (Jr.),
Defendant
: PROTECTION FROM ABUSE
CUSTODY ORDER
AND NOW, this ?O(~day of May, 1999, the following Order is entered by conscnt of'the
parties with rcgard to euslody of the parties' ehild, Isaiah Robert Lee Woodall.
I. Plaintill: hereinafter referred to as 1he mother, shall havc primary physical and legal
custody of the child.
2. Defendant, hereinafter rcferred to as thc father, shall have no contact with the child
pending further Order of Court.
By the Court,
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This Ordcr is entered pursuant to the consent of Plaintitf and Defendant:
S uzann
ryn Woodall, Plaintill'
~~~ J./~ ~;f"'
Robert Lee tllldall, II, (Jr.), Defendant
oah Carey, AUorney l' Plaintitr
LEGAL SERVICES, INC.
8 Irvine Row
Cllrlisle, PA 17013
(717) 243-9400
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SHERIFF'S RETURN - REGULAR
CASE NO: 1995-00557 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
WOODALL SUZANNE K
VS.
WOODALL ROBERT JR
DAWN KELL , Sheriff or Deputy Sheriff of
CL~BERLAND County, Pennsylvania, who being duly sworn according
to law, says, the within NOTICE OF HEARING AND ORDER, was served
upon WOODALL ROBER'!' JR the
defendant, at 7:47 HOURS, on the 18th day of May
1999 at 221 WALNUT STREET
CARLISLE, PA 17013 ,CUMBERLAND
County, Pennsylvania, by handing to ROBERT L. WOODALL II
a true and attested copy of the NOTICE OF HEARING AND ORDER,
together with PROTECTION FROM ABUSE, TEMPORARY PROTECTION FROM
ABUSE ORDER
and at the same time directing His attention to the contents thereof.
Additional Comments:
DEFENDANT STATED THAT HE WAS NOT IN POSSESSION OF ANY WEAPONS
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
So answers: ~
K. ~~~;~~t~ I
18.00
3.10
8.00
.00
$~~..I.U
05/19/1999
by
(~).t~Y~h~r~
Sworn and subscribed to before me
this ItJ'tL. day of'7h.'f
19 qq A.D.
O~lf' I ((I1tdf~v I..QA!l1
~ k'rot:lio~ot:ar:t'
SHERIFF'S RETURN - REGULAR
CASE NO: 1995-00557 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
WOODALL SUZANNE K
VS
WOODALL ROBERT JR
GERALD WORTHINGTON
, Sheriff or Deputy Sheriff of
cumberland County, Pennsylvania, who being duly sworn according to law,
says, the within PROTECTION FROM ABUSE
WOODALL ROBERT LEE II
was served upon
the
DEFENDANT
, at 0016:45 HOURS, on the 16th day of April
431 RAILROAD AVE
, 2001
at POE: GENCO
by handing to
SHIREMANSTOWN, PA 17011
ROBERT LEE WOODALL, II
a true and attested copy of PROTECTION FROM ABUSE
together with
NOTICE OF HEARING & ORDER, TEMP PFA, PETITION
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
So Answers: ~
r~-~~ 'c.I!
R. Thomas Kline
18.00
3.72
.00
10.00
.00
31.72
04/17/2001
Sworn and Subscribed to before
By:.A,....u-.ll)~
. Deputy S riff
me this .lJMI.. day of
(In..'f :kvl A.D.
OC)
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. I'rothonotary I
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Suzunne Kathryn Woodnll,
Plnintiff
: IN THE COURT OF COMMON
: PLEAS OF
: CUMBERLAND COUNTY,
: PENNSYLVANIA
v.
Robert Lee Woodall, 11
Dcfendant
: No. 95-557
: CIVIL ACTION - LAW
: PROTECTION FROM ABUSE
.
.
FINAL ORDER OF COURT
Dcfendant's Name is: Robert Lee Woodu\1 Il
Defendant's Date of Birth is: Februury 27. 1963
Defendant's Social Security Number is: 163-78-5865
Namc(s) of All protected persons, including Plaintiff and minor children:
1. Suzunne Kuthryn Wooda\1
AND NOW, this 24th Duy of April. 2001 thc court having jurisdiction over the
parties and thc subject-mallcr. it is ORDERED. ADJUDGED and DECREED us
follows:
Pursuant to consent of thc parties, which docs not constitutc Defcndant's
admission to thc averments of nbuse inthc petition. Thc following ordcr will be
entercd:
l'lulntlfrs request for a I1nu1 protection order Is grunted.
1. Dcfeadant sha\1 not abuse, stalk, harass,threatcn thc Plaintiff or any othcr
protectcd pcrson in any place whcrc thcy might be found.
2. Defendant is eomplctely evicted and excluded from thc residcnce at:
" ;"
20 East Street, #7
l\U. 1l0\1y, I'll.
or any other residcnce whcre Plaintiff or any other pcrson protected under
this Order lIIay live. Exclusive posscssion ofthc residence is grnnted to
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I'luintiff. Defendant shull huve no right or privilege to enter or be present on
lhe premises of Plaintiff or allY other person protecled under this Order.
3. Exeept as provided in Paragraph 4 of this Order, Defenduntls prohibited
from having ANY CONTACT with the Plaintiff, or any other person
protected under this Order,ut uny location, Including but not limited to any
eon1act ul Pluinlifrs school, business, or pluce of employement. Defendant is
spceilically ordered to stay uway from the following locutions for the
duration oflhis order.
Plalntlfrs residence loeuted ut 20 East Street, #7, !Ht Holly,
Pennsylvania.
Plalntlfrs place of emllloyment located at McDonald's, HIgh Street,
Carlisle, Pennsylvunlu.
4. Custody of the following minor children:
I. Brlahna Kathryn Woodull
shall be as follows:
. Primary physlcul custody of the minor chlld/ren Is
uwurded to the Plulntlff,
. Defendant shull have the following partial physical
eustody/vlsltutlon rights: At times und pluces mutually
ugreed upon by the parties and communleuted through
Defendunt's sister or mother,
. Transporatlon for Defendant's periods of partlul
physlcul custody sbull be urrunged und provided by
Defendant's sister or his mother.
5. The following additional relief is grantcd as authorized by ~6108 of the Act:
Defendant Is enjoined from damaging or destroying uny property owned
jointly by the purtles or owned solely by l'lalntlff,
Defendant Is to refrain from harusslng l'lalntlfrs relatives.
This order cun be extended beyond Its original explrutlon dute If the
court finds thut Defendant hus commUted unother act of ubuse or hns
enguged In a pultern or pructlce thutlndleutes continued risk or harm to
Plaintiff.
.
.
...
6. Dcfendant is directed to pay temporary support for:
1. BrIahna Kathryn Woodall
2. Isaiah Robcrt Woodall g.;)
-/,
as follows: , .~~.pUJ
Dcfendant shall pay $100.00~e a month to PlaIntiff for child support.
This order for support shall rcmain in cffcct until a final support order is
cntcrcd by this Court. Howcver, 1his order shall lapse automatically if the
Plaintiff docs not filc a complaint for support with the Domestie Relations
Section of the court within two wceks oflhe date ofthis ordcr. The amount of
this tcmporary order docs not neccssarily rcflect Dcfendant's correct support
obligation, which shall be dctcrmincd in aceordance with thc guidclines at thc
support hearing. Any adjustmcnls in thc final amount of support shall bc
creditcd, rclroaetive to this datc, to the appropriale party.
7. A certified copy of this Order shall bc provided to lhc police departmcnt
whcrc Plaintiffrcsidcs and any olher agcncy specified hcreafter:
Mt. Holly Police
Carlislc Borough Policc
North Mlddlcton Police
8. THIS ORDER SUPERSEDES:
1. ANY PRIOR PFA ORDER
9. All provisions of this order shall expirc on: October 25, 2002
NOTICE TO THE DEFENDANT
VIOLATION OF THIS ORDER MA Y RESULT IN YOUR ARREST ON THE
CHARGE OF INDIRECT CRIMINAL CONTEMPT WHICH IS
PUNISHABLE BY A FINE OF UP TO $1,000 AND/OR A JAIL SENTENCE
OF UP TO SIX MONTHS. 23 PA.C.S. ~6114. VIOLATION MAY ALSO
SUBJECT YOU TO PROSECUTION AND CRIMINAL PENALTIES UNDER
THE PENNSYL VANIA CRIMES CODE.
THIS ORDER IS ENFORCEABLE IN ALL FIFTY (50) STATES, THE
DISTRICT OF COLUMBIA, TRIBAL LANDS, U.S. TERRITORIES AND
THE COMMONWEALTH OF PUERTO RICO UNDER THE VIOLENCE
AGAINST WOMEN ACT, 18 U.S.C. ~2265. IF YOU TRA VEL OUTSIDE OF
THE STATE AND INTENTIONALL Y VIOLATE THIS ORDER, YOU MA Y
BE SUBJECT TO FEDERAL CRIMINAL PROCEEDINGS UNDER THAT
ACT. 18 U.S.C ~~2261.2262.IF THE BRADY INDICATOR PARAGRAPH
,\>, 'I
. .'
-
APPEARS IN TilE ORDER, YOU MAYBE SU13JECr TO FEDERAL
PROSECUTION AND PENALTIES UNDER TIlE "BRADY" PROVISIONS
OF THE GUN CONTROL ACT, 18 U.S.C. ~922(G), FOR POSSESSION,
TRANSPORT OR RECEIPT OF FIREARMS OR AMMUNITION.
NOTICE TO LAW ENFORCEMENT OFFICIALS
The police who havejurisdietion over the plnintifl's residence OR any locntion
where a violation ofthis order oceurs OR whcre the defendant Il1ny be located,
shall enforce this order. An arrest for violation ofParugraphs I through 4 of this
order may be without warrant, based soley on probable cause, whether or not
the violation is committed in the presence of the police. 23 Pa.C.S. ~6113.
Subsequent to nrrest, the police officer shall scize all weapons uscd or
thrcatened to be uscd during the violation of the protection order or during prior
incidents ofabusc. The shall maintain possession of the weapons until further
ordcr ofthis Court.
When the defendant is placed under arrest for violation of this order, the
defendant shall be taken to the appropriate authority or authorities before whom
defcndant is to be arraigncd. A "Complaint for Indirect Criminal Contempt"
shall then be completed and signed by the police officer OR the plaintiff.
Plaintifl's presence and signature arc not rcquired to file Ihe complaint.
If sufficient grounds for violation of this order arc allegcd, the defendant shall
be arraigned, bond set nud both parties givcn notice of the date of the hcaring.
If entered purSllantto thc consent 0
.,
~l'1d )L~uO-l~1
S nnc Kathryn Woodall, Plaintiff
4t/f5( tj~
Robcrt Lee Woodall, II, Defendant
Pro se
all Carey, Attome}J . I' Plnintiff
MidPenn Legal Sc . es
8 Irvine Row
Carlisle, PA 17013
&
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Distribution 10:
.MidPenn Legnl Services
-Faxed nnd Mailed to PSI'
-Robe/1 Lee Woodnll, Delcnduflt
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03101'2438026
04102400779
CIlNTIlAI, l'Il0CIlSS
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OFFICE OF '!liE PRC7l1iCt.OTAR'l
CUMBERLAND CXXJmi' COUR1liCXJSE
ONE CCXJR11-lCXJSE rolJARE
CARLISLE, PA. 17013-J387
(717) 240-6195
FAX (717) 240-6573
V I ATE ~ E COP 1 E R
TO;
PA STATE POLICE. Ce.,t, I'ltfJf:t.Sr..- ,..., p.1..S.
,
FAX I:
717-249-0779
~: CURTIS R. LONG
RE: PFA ORDERS
MESSAGE:
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OCIltain in1OnBtJCn. ltat .Is p;ivi.l.ap:l, an€icb1tial m:I ~ fmn djor'''''' ore urla" <wI '.......'e J&I. If
liB ~ d: this I1l!$!;lIIlJl is rot t1-e inlB~ m:.Ip.ient, )OJ are lmtby rot:llifrl trot crtI ~t.it:n.
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Suzanne KlIthryn Woodall,
Pluintiff
: IN TIlE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY,PENNSYLVANIA
VS.
: NO. 95-557
CIVIL TERM
Robcrt Lee Woodall, \I,
Defendant
: PROTECTION FROM ABUSE
~OTICE OF HEARING AND ORDER
YOU HAVE BEEN SUED IN COURT. If you wish to defend ugainstthe elllims sct forth
in the following papcrs, you must appear atthc hcaring schcduled hcrcin. If you fail to do so, thc
CaSC may procced against you and a FINAL Order may bc cntercd aguinst you granting thc relicf
rcqucstcd in the Petition. In purticular, you may bc evicted from your residcncc und lose othcr
important rights.
'J ' 1'1
A hcarlng 011 thIs muttcr Is schcduled 011 thc oo(} day or April, 2001, at
I; :'u l1.m., In Courtroom No. ~ 011 the 4'h Floor of thc Cumberland County
Courthouse, i Courthousc Squurc, Carlisle, Penllsylvunlu.
You MUST obcy the Order that is attached until it is modificd or terminated by thc court
aner notice and hearing. If you disobey this Order, the police may arrest you. Violation of this
Order may subjcct you to a eharge ofindireet criminul eontempt which is punishable by u fine of up
to $1,000.00 and/or up to six months in jail undcr 23 Pa.C,S. ~6114. Violation may also subject you
to prosecu1ion and eriminal penalties under thc Pennsylvania Crimes Codc. Under federal law, 18
U.S.C. ~2265,this Order is enforccable anywhere in the United States, triballunds, U.S. Territorics
and the Commonwealth ofPucrto Rico. If you travel outside oflhe state and intcntionally violate
this Order, you may be subjeetto federal criminal proceedings under the Violence Against Womcn
Act, 18 U.S.C. ~ 2261-2262.
You should tuke this puper to your lawyer ut OIlCC. You have the righ1to have a lawycr
reprcsent you at the hearing. Thc court will not, howevcr, appoint a lawyer for you. If you do not
havc a lawyer or eannot ufford one, go to or telephone thc office set forth below to find out wherc
you can getlcgal hclp. If you cannot find a lawycr, you may have to proceed without onc.
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avcnue, Carlisle, Pennsylvania 17013
Tclcphone Numbcr: (717)249-3166
AMERICANS WITH mSABlLlTIES ACT OF 1990
The Court of Common Pleas of Cumberland County is required by law to comply with the .
Americans with Disabilities Aet of 1990. For infornmtion ubout uccessiblc facilities and reasonable
acconll11odations uVllilable to disabled individuals having busincss before the eourt, plcusc contuc1
ollr ollicc. All arrangcments must bc mude alleast72 hours prior to any heuring or business before
thc court. You must u\lend the schellulcd confcrence or heuring.
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Suzannc Kathryn Woodall,
Plaintiff
: IN TIlE COURT OF COMMON
: PLEAS OF
: CUMBERLAND COUNTY,
: PENNSYLVANIA
v.
Robert Lee Woodall, II
Dcfendant
:No.
: CIVIL ACTION - LAW
: PROTECTION FROM ABUSE
.
,
TEMPORARY PROTECTION FROM ABUSE ORDER
Dcfendant's Name is: Robert Lec Woodall II
Defendant's Datc of Birth is: February 27, 1963
Defendant's Social Security Numbcr is: 163-78-5865
Name(s) of All protected persons, including Plaintiff ~nd minor children:
1. Suzannc Kathryn Woodall
AND NOW, on , (to, u~<<?o~sidcration oflhe attached Petition for
Protection from Ab e, the court hereby entcrs the following Temporary Order:
Plalntlfrs request for a temporary protection order Is granted.
1. Defendant shall not abuse, harass, stalk or threaten any of the ubovc persons in
any place where they might be found.
2. Defcndant shall be evicted and excludcd from the residcnce at:
20 East Street, #7
Mt. Holly, Pa,
or any other pcrmunen1 or temporary residcnce where Plainti ff or any othcr
person protected under this Order may live. Plaintiff is gran1ed cxclusive
possession oflhe residcnee. Defendant shall have no right or privilege to enter or
be present on the premises of Plaintiff or uny other pcrson proteetcd under this
Order.
3. Except for such contac1 with the minor childlrcn as may be permiUed under
paragraph 4 of this Order, Defendant is prohibited from having ANY CONTACT
with Plaintiff, or any other pcrson protected under this Order, at any locu1ion,
including but n01limitcd to any contac1 a1 Pluintifl's school, busincss, or placc of
employmcnt.
4. Pcnding thc outcomc of the final hearing in this muller, Plaintiff is awardcd
temporary custody of thc following minor childlren:
I. Brlahnu Kathryn Woodall
Until the final hearing, all contact betwcen Defendant and the childlren shall bc
Iimitcd to 1hc following:
No contact with thc child pending further ordcr of court.
The local law enforcemcnt agency in thc jurisdiction where the childlren arc
located shall cnsurc 1hat the childlren arc placed in the Care and control oflhc
Plaintiff in accordancc with thc Icons of this Ordcr.
5. The following additional relief is gran1ed:
Thc Cumbcrland County Sherifrs Dcpartmcnt shall attempt to makc servlec
at Plalntlfrs requcst and without pre-payment of fees, but service may bc
accomplished under any applicable Rule of Civil Procedurc,
This Ordcr shall bc docketed In the office of thc Prothonotary and forwarded
to the Shcriff for scrvlee. The Prothonotary shull not send a copy of this
ordcr to the Defendant by mall.
Defendant Is enjoined from damaging or destroying any property owned
Jointly by the parties or owned solely by Plaintiff.
Defendant Is to refrain from harassing Plulntlfrs relatives.
This order can be extended be)'ond Its original cxplratlon datc If the court
finds that Defcndant has eommllted another act of abuse or has
cngaged In a pattern or practice that Indicates continued risk of harm to
Plaintiff.
6, A certificd copy of this Order shall be provided to the police depurtment wherc
Plaintiff resides and any other agency specified hcreaOer:
Mt. Holly Police
Carllslc Borough Police
Norlh Middleton Pollee
7. Thc sheriff, police or othcr law enforcement ageneics are directcd to servc the
Defcndant with a copy of the Pe1ition, any Ordcr issued, and the Order for
Hearing without prepayment of eosts. The Peti1ioner will informthc dcsignated
authority of any addresses, other than the Defendan1's residcnce, where Dcfendant
can be served. The Prothonotary is directed to filc this Petition and Order without
prcpaymcnt of costs.
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8. THIS ORDER SUPERSEDES
ANY PRIOR PFA ORDER
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9. THIS ORDER APPLIES IMMEDIATELY TO DEFENDANT AND SHALL
REMAIN IN EFFECT UNTIL OCTOBER 16,2002 OR UNTIL OTHERWISE
MODIFIED OR TERMINATED BY TI'IIS COURT AFTER NOTICE AND
HEARING.
NOTICE TO THE DEFENDANT
Defendant is hereby notified that violation of this Order may result in arrest for
indirect criminal contcmpt, which is punishablc by a fine of up to $1,000.00 and/or
up to six months in jail. 23 Pa.C.S. ~6114. Conscnt ofthe Plaintiff to Defendant's
return to thc residence shall not invalidatc this Order, which can only be ehanged or
modified through the filing ofappropriatc court papers for that purposc. 23 Pa.C.S.
~6113. Dcfendant is furthcr notified that violation of this Ordcr may subject him/her
to slatc charges and pcnalties undcr thc Pennsylvania Crimes Codc and to federal
charges and penalties under thc Violence Against Women Aet, 18 U.S.C. ~~2261-
2262.
NOTICE TO LAW ENFORCEMENT OFFICIALS
This Order shall be cnforced by the poliee who havc jurisdiction over the plaintill's
residence OR any location where a violation of this order occurs OR where thc
dcfendant may bc located. If defcndant violatcs Paragraphs I through 4 of this
Order, dcfendant shall be arrestcd on'thc chargc of Indirect Criminal Contempt. An
arrest for violation of this Order may be madc withou1 warrant, based solcly on
probable cause, whether or not the violation is eommilled in the presencc oflaw
cnforeemen1.
Subsequent to an arres1, the law enforcement officer shall seize all wcapons used or
threatened to be uscd during thc violation of this Ordcr OR during prior ineidents of
abusc. Weapons must forthwith be delivered to the Shcrifrs office ofthc eounty
which issued this Order, which office shall maintain possession of the wcapons until
further Ordcr of this court, unless the weaponls are cvidencc of a erime, in which
case, they shall remain with thc law enforcement agency whose officer madc the
arrest.
BY TIll.! COURT
,
Dislribution to:
Joan Carcy, Altomey for Plaintiff
MidPenn Lcgal Services
8 Irvinc Row, Carli sic, PA 17013
FAXED and mailed to PSI' -L:) -CO P - Ll-/l.' 0 IRKs
PFAD Number: CDI229368P
Suzannc Kathryn Woodall,
Plainti ff
: IN TIlE COURT OF COMMON
: PLEAS OF
: CUMBERLAND COUNTY,
: PENNSYLVANIA
v.
Robert Lee Woodall, 11
Defendant
.
,
:No,
: CIVIL ACTION - LAW
: PROTECTION FROM ABUSE
,
.
PETITION FOR PROTECTION FROM ABUSE
\. Plaintirrs namc is:
Suzanne Kathryn Woodall
2. I, (thc Plaintifl), am filing this Petition on behalf of:
_ myself
3. Name(s) of ALL person(S), including minor children, who scek proteetion from abusc.
a, Suzanne Kathryn Woodall
4. Plaintirrs Addrcss is: 20 East Street, #7. Mt. 1I0lly, Pa 17065
5. Defendant's Namc is:
Robert Lee Woodall II
6. Defcndunt is believcd to live at the following addrcss:
20 East Street, #7, Mt. 1I0lly, I'a 17065
7. Defendant's Social Security Numhcr is:
163-711-51165
8. Dcfendan1's Dale of Birth is:
February 27, 1963
9. Dcfendant's Plaee ofcmploymcn1 is:
Genco. Mcehanlesburg, Pa. 17055
10. Dcfendant is an adult.
11. The rclationship betwccn the Plaintiff and the Defcndant is:
Spousc
12. The Plaintirrand the Dcfendant been involved in the following court actiono:
a. Protection From Abuse
13. Other de1ails of the court action arc:
Final Protcetlon Ordcr entered on May 28, 1999, No. 95-557 Civil Term, In
thc Court of Common Picas of Cumberland County, Pcnnsylvanla
14. Thc dcfendant has becn Involved In a criminal court action.
15. The dcfcndantls currently on probation I parole.
16. Thc defendant Is currently on County probation I parole.
Descrip1ion: Cumberland County, Pennsylvania
17. Plaintirrand Dcfendant are 1hc parents ofthc following minor childlren:
a. Brlahna Kathryn Woodall
Age:ll months
Child's address is: 501 Wagncr Drlvc, Carlisle, PA 17013
b. !slah Robert Woodall
Age:2 years
Child's addrcss is: 501 Wagncr Drive, Carlisle, PA 17013
18. Therc is an cxisting court order rcgarding the custody of the Plaintirrs and Dcfcndan1's minor
ehildren.
The tcrms ofthe ordcr lire: l'llllntlff has primary physical and leglll custody of Islllllh
Robert Lce Woodall according to Il Custody Order, No. 95-557, entered on May 28,1999,
In the Court of Common Pleas of Cumberland County, Pennsylvllnlll.
County: Cumberlllnd
State: Pennsylvllnlll
19. Plaintiff is sceking an Ordcr of child eustody as part of this petition.
The following is a list of the children IInd whcre they have Iivc for the past 5 YCllrs:
a. Brlllhna Kathryn Woodall
For the past 5 years, this child has Iivcd with:
Child has resided at the following IIddresses:
I)from May 7, 2000 to April 6, 200l,at 20 East Street, Mt. Holly, PA,
with Pllllnllff and Defcndant
2)from April 6, 2001 to prescnt at SOl Wagncr Drive, Carlisle, PA, with
Plaintiff and maternal grandparents.
20. The facts ofthc most recent incident of abuse are as follows:
On or about March 20,2001, Defcndant sexually assaulted Plaintiff, slappcd her In the
face, and repeatedly threlltened to take her life. l'llllntlff heard Defendant make Il phone
call and tell the person who answered that he needed to tllke the children Ilnd raise them
because he Was going to get rid of Plaintiff causing her to fear for her safety. Plaintiff Was
able to avoid Defendant for several days because he worked night shift and she worked
day shift. However, on or about April 6, 200l,Plalntlffwas concerned for her sllfety
when Defendant did not returned home for a few days Ilfter he hlld been Pllld. Based on
Defendant's past plltlern of abuse which escalated Ilfter he was Pllld, Plalnllff feared for
her safety and that of her children, left the residence with them, and went to stay with her
parents at 501 Wagner Drive, Cllrllsle,
Pennsylvania.
21. Prior incidents of abuse that the Defendant has commiued againstPlaintiffor thc minor
ehildlren. (including any threllts, injuries, or inciden1s of stalking) arc as follows:
In or about Mllrch 2000, when Plalnllff WIlS pregnant, Defendllnt repeatedl)' slapped her
In the face, choked her, and threlltened to throw her down a set of stairs,
Since approximately December 1993, Defendunt hils Ilbused Plaintiff In wllYs Including,
but not limited to shoving, grllbblng, slapping, punching, kicking, choking, pulling her
hlllr, Intimidating her, threatening to beat her, sexuall)' assaulting her, threlltenlng to kill
her by culling her throat while she sleeps Ilnd locking her and the children out of the
house, Defendunt's hlstor)' of abusive behllvlor eXlleerbates her fellr,
On 1\I1lY 17, 1999, l'lalnllff med Il Petition for Proteellon From Ahuse aglllnst Ilefendllnt
Ilt the Ilbove-lIsted uumber, Ilnd Il FlnlllProtectloll Order WIIS entered onMny 28. 1999,
22. Thc poJiec departmcnt{s) or law cnforcement agencies that should be provided with a copy of
thc protection order arc:
Mt. Holly Pollee
Carllsle Borough Police
North Middleton Police
23. There is an immediate and prcsent dangcr of furthcr abusc from the Defendant.
24. Plaintiff is asking 1he court to evict and excludc the Dcfendant from thc following residence:
20 East Street, #7
Mt. Holly, Pa.
Rented By:Suzanne Kathryn Woodall
25. Thc Dcfendant owes n duty of support to Plaintiff and/or minor child/rcn.
26. FOR THE REASONS SET FORTH ABOVE, I REQUEST THAT THE COURT ENTER
A TEMPORARY ORDER, and AFTER HEARING, A FINAL ORDER THAT WOULD
DO THE FOLLOWING:
a. Restrain Dcfcndant from abusing, threatcning, harassing, or stalking
Plaintiff and/or minor child/ren in any place wherc Plaintiff may be found.
b. Evict/excludc Dcfendant from Plaintilrs residcnce and prohibit Dcfcndant
from attempting to entcr allY temporary or pcmlDncnt residencc of the
Plaintiff.
c. Award Plaintiff temporary eustody ofthc minor child/ren and placc thc
following rcstric1ions on contact betwecn Dcfendant and child/rcn:
No contnet wllh chlldren pending further order of court.
d. Prohibit Defcndant from having any contact with Plaintiff and/or minor
child/ren, either in pcrson, by telephone, or in writing, personally or through
third pcrsons, including but not limited to any contaet at Plaintilrs school,
busincss, or placc of cmployment, cxcept as the court may find ncccssary
with respect to partinl custody and/or visitation with thc minor child/ren.
c. Order Dcfendant to pay tcmporary support to Plainti ff and/or thc minor
ehild/ren, including mcdical support .
f. Order thc following additional relief, not listed above:
The Cumberland County Sherlfrs Department shall attempt to make
service nt Plalntlfrs request and without pre-payment of fees, but
service may be accomplished under any applicable Rule ofClvll
Procedure,
,
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This Order shall be docketed In thc office or the l'rothonotnry and
forwarded to the Shcrlrr for service, Thc l>rothonotllry shlll1nat send II
cOllY or this order to the Dercndant by mall.
This order clln bc extended beyond Its original expiration dntc If the
conrtl1nds thnt Dcfendnnt hns committed nnother net or nbuse or has
engaged In a pattern or Ilrnetlce that Indlelltes contlnned risk or hnrm
to Plalntlrr,
Dcfcndnnt Is enjoined from damaging or destroying any prollerty
owned jointly by the parties or owned solely by Plalnllrf,
Defendnntls to refrain from hnrasslng Plalnurrs relntlves,
g. Grant such other relief as the court deems appropriate.
h. Order the police or other law enforcement agency to serve the Defendant
with a copy of this Petition, any Order issued, and the Order for Hearing.
The petitioner will inform the designated authority of any addresses, other
than the Defendant's residence, where Defendnnt can be served.
Date:
L/-}~ /0/
I I
Respectfully submitted,
,; n
'Y~V ~c..~t-~
vIoan Carey 11
Attorney for Plaintiff
MldPenn Legal Services
81rvine Row, Carlisle, PA 17013
(717) 243-9400
VERIFICATION
I verify that I am the Petitioner liS designatcd in the prcscnt action and thatthc faets and
statements containcd in the above Pe1ition are true and correct to thc best of my knowledge. I
understand that any falsc statemcnts are made subject to thc pcnulties of 18 Pa.C.S.~4904, relating
to unsworn falsification to uuthorities.
Datcd:
l//J~IQI
04/16/01 MON 14:34 FAX 717 240 6573
CUlIIr CO l1lOTIIONOTARV
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2571
[ 0119p2405331
( 03J9p2438a26
[ 04] 92490779
CIlNTRAI. PROCESS
L1lGAI. SERV ICES
PSI'
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OFF1CE OF 1HE PRanlO\OI'ARY
c;u.mER(AND cx:mrrY CXXJR1llCXJSE
ONE COORTHCXJSE SQUARE
CARLISLE, PA. 17013-3J87
(717) 240-6195
FAX (717) 240.6573
V I ^ TEL E cop I E R
'10:
PA STAtE POLICE . ('tf.,oJ/fA I fI,.e..u, .. /VI. Po /.., $.
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FAX ,:
717-249-0779
~: CURTIS R. LONG
RE: PFA ORDERS
MESSAGE :
..------
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---
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V.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
95-557 CIVIL TERM
CHARGE: INDIRECT CRIMINAL
CONTEMPT
SUZANNE KATHRYN WOODALL,
Plaintiff
ROBERT LEE WOODALL, II
Defendant
IN RE: INDIRECT CRIMINAL CONTEMPT/BAIL
ORDER OF COURT
AND NOW, September 13, 2001, the defendant having
appeared with Public Defender, Jessica B. Rhoades, Esquire, an
indirect criminal contempt hearing is set for September 25,
2001, at 11 o'clock a.m. in Courtroom Number 3. Bail is set at
$1000.00.
By the Court,
P.J.
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Michelle H. Sibert, Esquire
Senior Assistant District Attorney
Jessica B. Rhoades, Esquire
Assistant Public Defender
Probation
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Sheriff
CCP
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SUZANNE K. WOODALL,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
95-0557 CIVIL TERM
PROTECTION FROM ABUSE
v.
ROBERT L. WOODALL, II,
Defendant
IN RE: INDIRECT CRIMINAL CONTEMPT
ORDER OF COURT
AND NOW, September 25, 2001, Robert L. Woodall, II,
having appeared in open court together with the Public Defender,
Linda HOllinger, Esquire, on a complaint alleging indirect
criminal contempt of a PFA order of April 24, 2001, and the
defendant having admitted the allegation of the petition, we do
find the petition to be supported beyond a reasonable doubt.
Sentence of the court is that the defendant pay any costs
associated with the filing of this petition and that he undergo
imprisonment in the Cumberland County Prison for a period of not
less than ten days nor more than six months. We give him credit
for time served on this sentence from September 13, 2001, and we
now place him on parole to any other detainer or sentence
currently in effect. Part of his parole conditions shall be
that he undergo a D&A evaluation and comply with any
recommendation flowing therefrom. Sentence to be supervised
through the evaluation procedure and beyond, if more is
required.
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By the Court,
Michael W. Mervine, Esquire
Assistant District Attorney
Linda Hollinger, Esquire
Assistant Public Defender
Sheriff ~~ft,,~~-~e.1 ivcrc::.ct
~I~tim Services 1O Ii 0 to\
Probation ~~
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Suzunne Woodull,
: IN TIlE COURT OF COMMON PLEAS OF
Pluintiff
: CUMBERLAND COUNTY,PENNSYLVANIA
VS.
: NO. 1995557 CIVIL TERM
Robert Woodull, III,
: PROTECTION FROM ABUSE
Dcfendunt
URT
2002, upon eonsiderntion oflhe allached Petition,
thc FinalProtcctiol1 Order in the nbove-cuptioncd cuse entered on April 24, 200 I, is hercby vacated
and the action withdruwn without prejudice to Pluintiff.
By the Court,
.....-roan Carey
Allomey for Plaintiff
MIDPEN LEGAL SERVICES
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PRO SE DEFENDANT
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Suzanne Woodall,
: IN TIlE COURT OF COMMON PLEAS OF
Plaintiff
: CUMBERLAND COUNTY,PENNSYLVANIA
vs.
: NO. 1995557 CIVIL TERM
Robert Woodnll, III,
Defendan1
: PROTECTION FROM ABUSE
PETITION TO V ACA TE ORDER
AND WITHDRAW ACTION
Plaintiff, Suzanne Woodall, by and through her allomey, JOlin Curey of MidPenn Legal
Scrviccs, requests that the Cour1 vacute the FinalProtec1ion Order in the above-captioned case and
that the uelion be withdrawn on the grounds that:
I. A Petition for Protection From Abuse was filed und a Temporary Protection From
Abuse Order was issued by 1his Court on April 16, 200 I, schcduling a hearing for
April 25, 200 I, Presidcnt JudgeHoffer in Courtroom No.3 ofthe Cumberland County Courthouse.
A Final Protection Order was entcrcd on April 26, 2001, by agreement of the purties.
2. The pnrties are in the process of reconciling their differences.
3. Plaintiffrequests tlltlt the FinalProtcction Order be vacated and the action withdrawn
without prcjudice to her.
WHEREFORE, Plaintiffrcquests thaI the Court grant the relief requested and vacate
the Order, and that the action be withdrnwn withoU1 prejudice to Plaintiff.
Respectfully submiucd,
~~ /
Joan Curey, Allomey fori uintiff
I\III>1'ENN LEGAL SERVICES, INC.
8 Irvine Row
ClIrlisle,PA 17013
(717) 243-9400
YERIFICA TION.
I, verify that I 11I11 the Petitioncr ns designaled in the presenlnction nnd thntthe fncts nnd
statemcnts eontained in the ubove Petilion ure true nnd correct to 1he best of my knowledge. I
understand thntnny fulse slnlemenls nre mnde subjec110 the pennllies or I!lPn.C.S. *4904, relating
to unsworn falsificution to nlllhorilies.
Dated:
~,l}li I 00--
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lI~ne K. Woodnll, PlnintilT
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T.\tIlX NO
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200B
0110,'2400770
0310p2405331
0410243B026
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OFFICE OF' '!HE PR011lCN>TARY
CUMElERU\ND CCXMI'Y COl1llWOOSE
ONE COORWOOSE SQUARE
CARLISLE, PA. 17013-3387
(717) 240.6195
FAX (717) 240-6573
VIA TELECOP!ER
TO:
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PA STATE POLICE . Ct:AJ1~1f1
717-249-0779
PIt.1: US.
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rncz.I: CURTIS R. LONG
RE: PFA ORDERS
MESSAGE:
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NAME Kc>llr"yt L W.Ovtl,,!L I ,IT
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BALANCE DUE: $ 16-r. (p J.
VICTIM'S NAME:
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ADD DELETE
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170 STATE SURCHARGE
171 STATE FINE
260 SHERIFF COST ($1.50 + ADDTL)
207 DISTRICT ATTORNEY
204 COURT COSTS (CLERK OF COURTS)
502 RESTITU~ON
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