HomeMy WebLinkAbout95-00824
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DEBRA NORNHOLD,
Plaintiff
for herself and on behalf
of her minor children:
IRENE WOLFE
ROBERT WOLFE, JR.
HARLEY WOLFE
vs.
ROBERT J. WOLFE, SR.,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 95- '6J~ CIVIL TERM
PROTECTION FROM ABUSE
AND CUSTODY
AND NOW, this
TEMPORARY PROTECTION ORDER
\., t\. day of February, 1995, upon
presentation and consideration of the within Petition, and upon
finding that the plaintiff, DEBRA NORNHOLD, and the minor
children, now residing at an undisclosed location, Cumberland
county, pennsylvania, is in immediate and present danger of abuse
from the defendant, ROBERT J. WOLFE, SR., the following Temporary
Order is entered. Law enforcement agencies, human service
agencies and school districts shall not disclose the presence of
the plaintiff or the children in the jurisdiction or district or
furnish any address, telephone number, or any other demographic
information about the plaintiff and children except by further
Order of Court.
The defendant, ROBERT J. WOLFE, SR., DOB: 4/2/67, now
residing at 56 B Hall Manor, Harrisburg, Dauphin County,
Pennsylvania, is hereby enjoined from physically abusing the
plaintiff, DEBRA NORNHOLD, or the children, or placing them in
fear of abuse.
The defendant is ordered to stay away from any residence the
plaintiff has now or may establish for herself in the future.
communications.
The defendant is enjoined from harassing and stalking the
plaintiff and from harassing the plaintiff's relatives.
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.S. 56113.1; iii) a charge of indirect oriminal
contempt under 23 Pa. c.S. 56114, punishable by imprisonment up
to six months and a fine of $100.00-$1,000.00; and iv) civil
contempt under 23 Pa. C.S. 56114.1. Resumption of co-residence
on the part of the plaintiff and defendant shall not nullify the
p~ovisions of the court order.
The defendant is ordered to refrain from having any direct
or indirect contact with the plaintiff or the minor children
including, but not limited to, telephone and written
Temporary eustody of IRENE, ROBERT, JR., and HARLEY WOLFE,
is hereby awarded to the plaintiff, DEBRA NORNHOLD.
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 ~1j~ day of February, 1995, at,S:1~
~
CL .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 proeedure.
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 appropriate police Departments where the plaintiff lives
and works 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,
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DEBRA NORNHOLD,
Plaintiff
for herself and on behalf
of her minor children:
IRENE WOLFE
ROBERT WOLFE, JR.
HARLEY WOLFE
vs.
ROBERT J. WOLFE, SR.,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 95-
CIVIL TERM
PROTECTION FROM ABUSE
AND CUSTODY
NOT ICE
You have been sued in court. If you wish to defend against
the claims set forth in the following pages, you must take action
promptly after this Petition, Order and Notice are served, by
appearing personally or by attorney at the hearing scheduled by
the Court and presenting to the Court your defenses or objections
to the claims set forth against you. You are warned that if you
fail to do so the Court may proceed without you, and a judgment
may be entered against you by the Court without further notice
for any money claimed in the Petition or for any other claim or
relief requested by the plaintiff. You may lose money or
property or other rights important to you.
FEES 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 plaintiff.
You should take this paper to your lawyer at once. If you
do not have a lawyer or cannot afford one, qo to or telephone the
office set forth below to find out where you can qet leqal help.
COURT ADMINISTRATOR, 4th FLOOR
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PENNSYLVANIA 17013
TELEPHONE NUMBER: (717) 240-6200
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DEBRA NORNHOLD,
plaintiff
for herself and on behalf
of her minor children:
IRENE WOLFE
ROBERT WOLFE, JR.
HARLEY WOLFE
vs.
ROBERT J. WOLFE, SR.,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 95-(;';)L/ CIVIL TERM
PROTECTION FROM ABUSE
AND CUSTODY
PETITION FOR PROTECTION ORDER
AND CUSTODY
RELIEF UNDER THE PROTECTION FROM ABUSE
ACT, 23 P.S. S 6101 at seq.
A. ABUSE
1. The plaintiff, DEBRA NORNHOLD, is an adult individual
residing at an undisclosed location.
2. The plaintiff is temporarily staying at an undisclosed
location for her own protection and to avoid further abuse as is
more fully set forth herein. This address will be furnished to
the court upon request.
J. The defendant, ROBERT J. WOLFE, SR., DOB: 4/2/67, is an
adult individual residing at 56B Hall Manor, Dauphin county,
Pennsylvania, 17103.
4. The defendant is the father of the plaintiff's children.
5. Sinee approximately 1991, the defendant has attempted to
cause and has intentionally, knowingly, or recklessly caused
bodily injury to the plaintiff and the minor children, placed the
plaintiff and the minor children in reasonable fear of imminent
serious bodily injury, and has knowingly engaged in a course of
conduct or repeatedly committed acts toward the plaintiff and the
minor children under circumstances which have placed the
plaintiff and the children in reasonable fear of bodily injury.
This has included, but is not limited to, the following specific
instances of abuse:
a. On or about January 2, 1995, the defendant hit the three
year-old in the chest with his fist, causing the child to
cry. Later, the defendant became angry at the plaintiff,
pushed the plaintiff in the chest, grabbed items from the
plaintiff's hands, threw the items about the room, and
threatened the plaintiff saying, "If I find you in
Harrisburg, I will beat you up and take the kids." The
plaintiff and her children left the residence.
b. In or around Christmas, 1994, the defendant pushed the
plaintiff into a wall and steps. Later, the defendant
cornered the plaintiff and drew back his fist several times
as if to hit the plaintiff.
c. In or around Thanksgiving, 1994', the defendant slapped
the plaintiff in the head, causing soreness and swelling.
d. Approximately two times per month since 1991, the
defendant has abused the plaintiff in ways including, but
not limited to, the following: pushing, slapping, grabbing,
punching, kicking, and preventing the plaintiff from leaving
the residence. On several occasions, the defendant caused
serious injury to the plaintiff including breaking the
plaintiff's nose, chipping her tooth, and breaking her
finger.
e. The defendant, on approximately a bi-weekly basis,
abuses the children by slapping them in the face leaving his
hand print and throwing the baby from a distance of
approximatelY two feet, into the crib.
6. On or about January 2, 1995, the plaintiff and the three
minor children left their residence at 1128 Clovery Road,
Harrisburg, Dauphin county, pennsylvania, in order to avoid
further abuse.
7. The plaintiff believes and therefore avers that she and
the minor children are in immediate and present danger of abuse
from the defendant, and that they are in need of protection from
such abuse.
B. The plaintiff desires that the defendant be prohibited
from having any direct or indirect contact with the plaintiff or
the minor children including, but not limited to, telephone and
written communications.
9. The plaintiff desires that the defendant be enjoined
from harassing and stalking the plaintiff, and from harassing the
plaintiff's relatives.
B. ~~~T
10. The defendant has a duty to support the minor children.
11. The defendant is employed at The Patriot News and the
plaintiff is unaware of his salary.
12. The plaintiff currently has no income.
13. The plaintiff intends to petition for support within
two weeks of the issuance of a protective order.
C. ATTORNEY FEES
14. The plaintiff asks that the defendant be ordered to pay
reasonable attorney fees to Legal services, Inc.
D. TEMPORARY CUSTODY
15. The plaintiff seeks temporary custody of the following
children:
Name
Present Residence
Aqe
"
IRENE WOLFE
ROBERT WOLFE, JR.
HARLEY WOLFE
undisclosed location
undisclosed location
undisclosed location
4 yrs.
2 yrs.
1 1/2 yrs
The children were born out of wedloek.
The children are presently in the custody of the
plaintiff, DEBRA NORNHOLD, who resides at an undisclosed
location.
During the children's lives, the children have resided with
the following persons and at the following addresses:
Name
plaintiff,
defendant, &
roommate
Addresses
Dates
Harrisburg, PA
5/30/90 - 6/90
plaintiff,
defendant &
another couple
crescent street
Harrisburg, PA
6/90 - 8/90
plaintiff &
defendant
Hooverter Homes
Harrisburg, PA
clovery Road
Harrisburg, PA
undisclosed loeation
8/90 - 5/94
plaintiff &
defendant
5/94- 1/95
plaintiff
1/95 - present
The mother of the children is DEBRA NORNHOLD, currently
residing at an undisclosed location.
She is single.
The plaintiff currently resides with the following
persons:
Name
IRENE WOLFE
ROBERT WOLFE, JR.
HARLEY WOLFE
Relationshin
daughter
son
son
The father of the children is ROBERT WOLFE, SR., currently
residing at 56 B Hall Manor, Harrisburg, Pennsylvania.
He is single.
The defendant currently resides by himself.
16. The plaintiff has not previously participated in any
litigation concerning custody of the above mentioned children in
this or any other Court.
17. The plaintiff has no knowledge of any custody
proceedings concerning these children pending before a court in
this or any other jurisdiction.
18. The plaintiff does not know of any person not a party
to this action who has physical custody of the children or claims
to have custody or visitation rights with respect to the
children.
19. The best interests and permanent welfare of the minor
children will be met if custody is temporarily granted to the
plaintiff pending a hearing in this matter for reasons including:
a. The plaintiff is a fit parent who can best take
care of the minor children.
b. The defendant has shown by his abuse of the
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plaintiff that he is not an appropriate role model for
the minor children.
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c. The defendant's behavior has adversely affected
the children.
WHEREFORE, pursuant to the provisions of the "Protection
from Abuse Act" of October 7, 1976, 23 P.S. S 6101 et seq., 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 and the minor children or placing them in fear of
abuse;
2. Ordering the defendant to refrain from having any
direct or indirect contact with the plaintiff or the minor
children including, but not limited to, telephone and
written communications;
3. Ordering the defendant to refrain from harassing
and stalking the plaintiff and from harassing the
plaintiff's relatives;
4. Prohibiting the defendant from removing, damaging,
destroying or selling property jointly owned by the parties
or owned solely by the plaintiff;
5. ordering the defendant to stay away from any
residence the plaintiff has now or may establish for herself
in the future;
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6. Granting temporary custody of the minor children
to the plaintiff;
B. Schedule a hearing in accordanee 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 the minor children and placing them in fear of
abuse.
2. Ordering the defendant to refrain from having any
direct or indirect contact with the plaintiff or the minor
children including, but not limited to, telephone and
written communications.
3. Ordering the defendant to refrain from harassing
and stalking the plaintiff and from harassing the
plaintiff's relatives.
4. prohibiting the defendant from removing, damaging,
destroying or selling property jointly owned by the parties
or owned solely by the plaintiff.
5. ordering the defendant to stay away from any
residence the plaintiff has now or may establish for herself
in the future.
6. Granting support to the minor children in an
appropriate amount according to the support guidelines.
7. 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 appropriate police
Departments in the areas where the plaintiff lives and works to
enforce this Order.
The plaintiff prays for sueh other relief as may be just and
proper.
COUNT II
CUSTODY UNDER PENNSYLVANIA CUSTODY LAW
20. The allegations of Count I above are incorporated
herein as if fully set forth.
21. The best interest and permanent welfare of the minor
children will be served by confirming custody in the plaintiff as
set forth in paragraph 19 of the petition.
WHEREFORE, pursuant to 23 P.S. S 5301 ~ sea., and other
applicable rules and law, the plaintiff prays this Honorable
Court to award custody of the minor children to her.
The plaintiff prays for such other relief as may be just and
proper.
Respeetfully submitted,
Ol~'L-)j (qILh";,-..,
J an Carey, Attorney r plaintiff
(IJ GAL SERVICES, INC.
B Irvine Row
carlisle, PA 17013
(717) 243-9400
The above-named plaintiff, DEBRA NORNHOLD, verifies that the
statements made in the above Petition are true and eorreet. The
plaintiff understands that false statements herein are made
subjeet to the penalties of 18 Pa. C.S. g 4904 relating to
unsworn falsifieation to authorities.
Date: '2.- CJ- '15"
jj~~'l~ rkMJk1JLoPJ
Debra Nornhold, Plaintiff
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SliER IFF' S RE'rURN
COMMONWEAL~'1l OF PENNSYLVANIA
COUNTY OF CUMBERLAND
In the Court of Common Pleas of
Cumberland County, Pennsylvnaia
No. 95-824 Civil Term
behalf Temporary Proteetion Order
Robert Proteetion from Abuse and Custody
Notice and Petition for Protection
Order and Custody and Continuanee
Order
Debra Nornhold, for herself and on
of her minor ehildrenl Iren Wolfe,
Wolfe Jr. and Ilarlcy Wolfe
VS
Robert J. Wolfe Sr.
R. THOMAS KLINE, Sheriff, who being duly sworn aceording to law,
says; that he made diligent search and inquiry for the within named
defendant, to witl
Robert J. Wolfe Sr.
but was unable to loeate
him
in his bailiwiek. He therefore
deputized the sheriff of Dauphin
County, Pennsylvania,
to serve the within Temporary Protection Order proteetion from
Abuse and Custody, Notlee and PetltlOn for protectiuu OLd"" aud
Custody and Continuanee Order
On
Mareh '3, 1995
, this office was in receipt of
the attaehed return from
Dauphin
County, Pennsylvania.
Sheriff's COStSI
Doeketing
Out of County
Surcharge
So answers I
18.00
9.00
:>E
,. .:...'~;-.t'''
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to '.--'. L"" :/t__
IR. THOMAS KLINE, Sheriff
$27,00
Sworn and subseribed to before me
this J r!:
day of 7/l.."J-'
19
9{ ,A.D.
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Prothonotary
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COMMONWEALTII 01: PENNA:
COUNTY OF DAUPIIIN:
SIIERIFF'S RETURN
NO. 95-274
PAGE 95
AND NOW: February 28th
10 95 .lIt 9:04 A. ~1.
SIlRVED Tim
WITIIIN
Order for Continuance
UPON
-.-------...--......- ..... -...... ...-.. .......-....--...--
Robert J. l~o1fe, Sr. BY PERSONALI,Y
HANDING TO
Robert J. l~o1fe, Sr.
A TRUE ATTESTED COpy OF THE ORIGINAl,
Order for Continuance
AND MAKING KNOWN TO
him
'fllE CONTENTS TlllmllOF AT his place of
employment, Kentucky Fried o,icken, 6th Street, Harrisburg, Pa.
so ANSWliRS '
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I~~E~OF DAUPH I N C~~~~?' I :E'NNA
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DEPUTY SIIIlIlIFF
Sworn and subscribed to
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~110No.rAlIY
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SlIliIllFF'S COST $)//c...
S-IA
III in;!)' Court or C.::mmO~l
Debra Nornhold, et. al.
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'Vs.
Robert J. Wolfe, Sr.
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95-274 Civil Tenn
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February 24, 1995
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DEBRA NORNHOLD,
Plaintiff
for herself and on behalf
of her minor children:
IRENE WOLFE
ROBERT WOLFE, JR.
HARLEY WOLFE
vs.
ROBERT J. WOLFE, SR.,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 95- 8J~ CIVIL TERM
PROTECTION FROM ABUSE
AND CUSTODY
TEMPORARY PROTECTION ORDER
AND NOW, this J~~h day of February, 1995, upon
presentation and consideration of the within Petition, and upon
fin1ing that the plaintiff, DEBRA NORNHOLD, and the minor
children, now residing at an undisclosed location, Cumberland
County, Pennsylvania, is in immediate and present danger of abuse
from the defendant, ROBERT J. WOLFE, SR., the following Temporary
Order is entered. Law enforcement agencies, human service
agencies and school districts shall not disclose the presence of
the plaintiff or the children in the jurisdiction or district or
furnish any address, telephone number, or any other demographic
information about the plaintiff and children except by further
Order of Court.
The defendant, ROBERT J. WOLFE, SR., DOB: 4/2/67, now
residing at 56 B Hall Manor, Harrisburg, Dauphin county,
Pennsylvania, is hereby enjoined from physically abusing the
plaintiff, DEBRA NORNHOLD, or the children, or placing them in
fear of abuse.
The defendant is ordered to stay away from any residence the
plaintiff has now or may establish for herself in the future.
!
.
The defendant is ordered to refrain from having any direct
or indirect contact with the plaintiff or the minor children
including, but not limited to, telephone and written
communications.
The defendant is enjoined from harassing and stallcing the
plaintiff and from harassing the plaintiff's relatives.
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.s. 56113.1; iii) a charge of indirect criminal
contempt under 23 Pa. C.S. 56114, punishable by imprisonment up
to six months and a fine of $100.00-$1,000.00; and iv) civil
contempt under 23 Pa. C.S. 56114.1. Resumption of co-residence
on the part of the plaintiff and defendant shall not nullify the
provisions of the court order.
Temporary custody of IRENE, ROBERT, JR., and HARLEY WOLFE,
is hereby awarded to the plaintiff, DEBRA NORNHOLD.
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 ~4~h day of February, 1995, at ~ji
A .m., in Courtroom NO~, Cumberland County Courthouse,
Carlisle, Pennsylvania.
The plaintiff may proeeed 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 aceomplished 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 appropriate Police Departments where the plaintiff lives
and works 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,
119' LUM/'; 6~/. 9"
I Judge
TRUE COpy FROM RECOR1)
I Tesllmony \111101001, I here lltllO Silt mv !'.and
,~~(j lho seal 01 s:!id Gr.t'.tI at C:II'II~!p" r?~
l;il~ ,.J.'I.l.!.:.....'J'ly, r.1 ! .e IL.. I !l-:-2-
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Prothonotary
DEBRA NORNHOLD,
plaintiff
for herself and on behalf
of her minor children:
IRENE WOLFE
ROBERT WOLFE, JR.
HARLEY WOLFE
vs.
ROBERT J. WOLFE, SR.,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 95-
CIVIL TERM
PROTECTION FROM ABUSE
AND CUSTODY
.
.
NOT ICE
You have been sued in court. If you wish to defend against
the claims set forth in the following pages, you must take action
promptly after this Petition, Order and Notice are served, by
appearing personally or by attorney at the hearing scheduled by
the Court and presenting to the Court your defenses or objections
to the claims set forth against you. You are warned that if you
fail to do so the Court may proceed without you, and a judgment
may be entered against you by the court without further notice
for any money claimed in the Petition or for any other claim or
relief requested by the plaintiff. You may lose money or
property or other rights important to you.
FEES 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 plaintiff.
You should take this papur to your lawyer at once. If you
do not have a lawyer or cannot afford one, qo to or telephone the
office set forth below to find out where you can qet leqal help.
COURT ADMINISTRATOR, 4th FLOOR
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PENNSYLVANIA 17013
TELEPHONE NUMBER: (717) 240-6200
. ..... .... . --.. '.
DEBRA NORNHOLD,
plaintiff
for herself and on behalf
of her minor children:
IRENE WOLFE
ROBERT WOLFE, JR.
HARLEY WOLFE
vs.
RO~ERT J. WOLFE, SR.,
Defendant
:
IN THE COURT OF COMMON PLEAS of
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 95-
CIVIL TERM
PROTECTION FROM ABUSE
AND CUSTODY
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PETITION POR PROTECTION ORDER
AND CUSTODY
RELIEP UNDER THE PROTECTION PROM ABUSE
ACT, 23 P.S. S 6101 et seq.
A. ABUSE
1. The plaintiff, DEBRA NORNHOLD, is an adult individual
residing at an undisclosed location.
2. The plaintiff is temporarily staying at an undisclosed
location for her own protection and to avoid further abuse as is
more fully set forth herein. This address will be furnished to
the court upon request.
3. The defendant, ROBERT J. WOLFE, SR., DOB: 4/2/67, is an
adult individual residing at 56B Hall Manor, Dauphin county,
,
Pennsylvania, 17103.
4. The defendant is the father of the plaintiff's children.
5. since approximately 1991, the defendant has attempted to
cause and has intentionally, knowingly, or recklessly caused
bodily injury to the plaintiff and the minor children, placed the
plaintiff and the minor children in reasonable fear of imminent
serious bodily injury, and has knowingly engaged in a course of
conduct or repeatedly committed acts toward the plaintiff and the
minor children under circumstances which have placed the
plaintiff and the children in reasonable fear of bodily injury.
This has included, but is not limited to, the following specific
instances of abuse:
a. On or about January 2, 1995, the defendant hit the three
year-old in the chest with his fist, causing the child to
cry. Later, the defendant became angry at the plaintiff,
pushed the plaintiff in the chest, grabbed items from the
plaintiff's hands, threw the items about the room, and
threatened the plaintiff saying, "If I find you in
Harrisburg, I will beat you up and take the kids." The
plaintiff and her children left the residence.
b. In or around Christmas, 1994, the defendant pushed the
plaintiff into a wall and steps. Later, the defendant
cornered the plaintiff and drew back his fist several times
as if to hit the plaintiff.
c. In or around Thanksgiving, 1994, the defendant slapped
the plaintiff in the head, causing soreness and swelling.
d. Approximately two times per month since 1991, the
defendant has abused the plaintiff in ways including, but
not limited to, the following: pushing, slapping, grabbing,
punching, kicking, and preventing the plaintiff from leaving
the residence. On several occasions, the defendant caused
serious injury to the plaintiff including breaking the
plaintiff's nose, chipping her tooth, and breaking her
finger.
e. The defendant, on approximatelY a bi-weekly basis,
abuses the children by slapping them in the faee leaving his
hand print and throwing the baby from a distanee of
approximately two feet, into the crib.
6. On or about January 2, 1995, the plaintiff and the three
minor children left their residence at 1128 Clovery Road,
Harrisburg, Dauphin county, Pennsylvania, in order to avoid
further abuse.
7. The plaintif~ believes and therefore avers that she and
the minor children are in immediate and present danger of abuse
from the defendant, and that they are in need of protection from
such abuse.
8. The plaintiff desires that the defendant be prohibited
from having any direct or indirect contact with the plaintiff or
the minor children including, but not limited to, telephone and
written communications.
9. The plaintiff desires that the defendant be enjoined
from harassing and stalking the plaintiff, and from harassing the
plaintiff's relatives.
B. SUPPORT
10. The defendant has a duty to support the minor children.
11. The defendant is employed at The Patriot News and the
plaintiff is unaware of his salary.
12. The plaintiff currently has no income.
13. The plaintiff intends to petition for support within
two weeks of the issuance of a protective order.
C. ATTORNEY FEES
14. The plaintiff asks that the defendant be ordered to pay
reasonable attorney fees to Legal services, Inc.
D. TEMPORARY CUSTODY
15. The plaintiff seeks temporary custody of the following
children:
IRENE WOLFE
ROBERT WOLFE, JR.
HARLEY WOLFE
Present Residence
undisclosed location
undisclosed location
undisclosed location
M!!
Name
4 yrs.
2 yrs.
1 1/2 yrs
The children were born out of wedlock.
The children are presently in the custody of the
plaintiff, DEBRA NORNHOLD, who resides at an undisclosed
location.
During the children's lives, the children have resided with
the following persons and at the following addresses:
HA!H
plaintiff,
defendant, &
roommate
Addresses
Dates
Harrisburg, PA
5/30/90 - 6/90
plaintiff,
defendant &
another couple
Creso:ent Street
Harrisburg, PA
6/90 - 8/90
plaintiff
Hooverter Homes
Harrisburg, PA
clovery Road
Harrisburg, PA
undisclosed location
8/90 - 5/94
plaintiff &
defendant
plaintiff &
defendant
5/94- 1/95
1/95 - present
The mother of the children is DEBRA NORNHOLD, currently
residing at an undisclosed loeation.
She is single.
The plaintiff currently resides with the following
persons:
IW!l.@
IRENE WOLFE
ROBERT WOLFE, JR.
HARLEY WOLFE
RelationshiD
daughter
son
son
The father of the children is ROBERT WOLFE, SR., currently
residing at 56 B Hall Manor, Harrisburg, Pennsylvania.
He is single.
The defendant currently resides by himself.
16. The plaintiff has not previously participated in any
litigation concerning custody of the above mentioned children in
this or any other Court.
17. The plaintiff has no knowledge of any custody
proceedings concerning these children pending before a court in
this or any other jurisdiction.
18. The plaintiff does not know of any person not a party
to this action who has physical custody of the children or claims
to have custody or visitation rights with respect to the
children.
19. The best interests and permanent welfare of the minor
children will be met if custody is temporarily granted to the
plaintiff pending a hearing in this matter for reasons including:
a. The plaintiff is a fit parent who can best take
care of the minor children.
b. The defendant has shown by his abuse of the
plaintiff that he is not an appropriate role model for
the minor children.
c. The defendant's behavior has adversely affected
the children.
WHEREFORE, pursuant to the provisions of the "Protection
fl'om Abuse Act" of October 7, 1976, 23 P.S. S 6101 et sea., 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 and the minor children or placing them in fear of
abuse;
2. ordering the defendant to refrain from having any
direct or indirect contact with the plaintiff or the minor
children including, but not limited to, telephone and
written communications;
3. Ordering the defendant to refrain from harassing
and stalking the plaintiff and from harassing the
plaintiff's relatives;
4. Prohibiting the defendant from removing, damaging,
destroying or selling property jointly owned by the parties
or owned solely by the plaintiff;
5. Ordering the defendant to stay away from any
residence the plaintiff has now or may establish for herself
in the future;
6. Granting temporary custody of the minor children
to the plaintiff;
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 the minor children and placing them in fear of
abuse.
2. Ordering the defendant to refrain from having any
direct or indirect contact with the plaintiff or the minor
children including, but not limited to, telephone and
written communications.
3. Ordering the defendant to refrain from harassing
and stalking the plaintiff and from harassing the
plaintiff's relatives.
4. Prohibiting the defendant from removing, damaging,
destroying or selling property jointly owned by the parties
or owned solely by the plaintiff.
5. Ordering the defendant to stay away from any
residence the plaintiff has now or may establish for herself
in the future.
6. Granting support to the minor children in an
appropriate amount according to the support guidelines.
7. 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 appropriate Police
Departments in the areas where the plaintiff lives and works to
enforce this Order.
The plaintiff prays for such other relief as may be just and
proper.
COUNT II
CUSTODY UNDER PENNSYLVANIA CUSTODY LAW
20. The allegations of Count I above are incorporated
herein as if fully set forth.
21. The best interest and permanent welfare of the minor
children will be served by confirming custody in the plaintiff as
set forth in Paragraph 19 of the Petition.
WHEREFORE, pursuant to 23 P.S. S 5301 et ~., and other
applicable rules and law, the plaintiff prays this Honorable
Court to award custody of the minor children to her.
The plaintiff prays for such other relief as may be just and
proper.
Respeetfully submitted,
a~ ?J (L-'~_
~ an Carey, Attorney r Plaintiff
,~GAL SERVICES, INC.
a Irvine Row
Carlisle, PA 17013
(717) 243-9400
I,
OFFIC:I' or Tilt Sl/t'IIIFI'
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FEo /5 10 II AN '95
G,::" "j I
PENli.', i L fl\I:"!"
.,
DEBRA NORNHOLD, IN THE COURT OF COMMON PLEAS OF
plaintiff
for herself and on behalf of CUMBERLAND COUNTY, PENNSYLVANIA
her minor ehildren:
IRENE WOLFE, ROBERT WOLFE, JR.: NO. 95-824 CIVIL TERM
HARLEY WOLFE
v.
ROBERT J. WOLFE, SR.,
Defendant
PROTECTION FROM ABUSE AND
CUSTODY
ORDER FOR CONTINUANCE
AND NOW, this ~4f\l day of Mareh, 1995, upon consideration
of the attaehed Motion for continuanee, the hearing scheduled for
Mareh 28, 1995, at 2:30 p.m., is generally eontinued to afford
the parties time to exeeute a Consent Agreement. The Temporary
proteetive Order will remain in effect pending further order of
Court.
A eopy of this Order for Continuance will be provided to the
appropriate poliee departments in the areas where the plaintiff
lives and works by the plaintiff's attorney.
By ;he :::;t. ~ ~~
~tel;~rO
~
,
OEBRA NORNHOLD, IN THE COURT OF COMMON PLEAS OF
plaintiff
for herself and on behalf of CUMBERLAND COUNTY, PENNSYLVANIA
her minor ehildren:
IRENE WOLFE, ROBERT WOLFE, JR.: NO. 95-824 CIVIL TERM
HARLEY WOLFE
v.
ROBERT J. WOLFE, SR.,
Defendant
PROTECTION FROM ABUSE AND
CUSTOOY
MOTION FOR CONTINUANCE
The plaintiff moves this Court for an Order eontinuing the
hearing of this case until further Order of Court, on the grounds
that:
1. A Temporary Proteetion Order was issued by this Court on
the 15th day of February, 1995, scheduling a hearing for the 24th
day of February, 1995, at 8:45 a.m.
2. The defendant was served with the Temporary Protection
Order, eontacted Legal Serviees, Inc., and agreed to enter into
a Consent Agreement, but the defendant is unable to execute the
agreement before the seheduled hearing.
3. The plaintiff agrees that a general eontinuance be
granted upon condition that the Temporary Proteetion Order
remains in effeet pending further order of eourt.
4. A copy of the Order for Continuance will be delivered to
the appropriate police departments in the areas where the
plaintiff lives and works by the attorney for the plaintiff.
WHEREFORE, the plaintiff moves this Court to grant the
plaintiff's Motion, and to eontinue this matter until further
Order of Court.
~J~/'
~arey ~
Attorney for Plaintiff
LEGAL SERVICES, INC.
a Irvine Row
Carlisle PA 17013
(717) 243-9400
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DEBRA NORNHOLD,
IN THE COURT OF COMMON PLEAS OF
Plaintiff
for herself and on behalf of
her minor ehildren:
IRENE WOLFE, ROBERT WOLFE, JR.
HARLEY WOLFE
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 95-824 CIVIL TERM
v.
ROBERT J. WOLFE, SR.,
Defendant
PROTECTION FROM ABUSE AND
CUSTODY
ORDER OF COURT
AND NOW, upon consideration of the attached complaint, it is hereby directed
that the parties and their respective counsel appear before .....!.Q<l..(AI1) ), Svwfeyt:f"
il"J .. <~kIf1 /l '
the eonel1iator, at 3'1 LV M';n.5t-M'c 'on the::?5/1... day of ..uer,J
1995, at -1I,~A.m., for a Pre-Hearin9 Custody Conferenee. At such conference, an
effort will be made to resolve the issues in dispute; or if this cannot be
accomplished, to define and narrow the issues to be heard by the court, and to enter
into a temporary order. Failure to appear at the conference may provide grounds for
entry of a temporary or permanent order.
By the Court,
~xiw~
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND
OUT WHERE YOU CAN GET LEGAL HELP.
COURT ADMINISTRATOR, 4th FLOOR
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PENNSYLVANIA 17013
TELEPHONE NUMBER: (717) 240-6200
AMERICANS WITH DISABILITIES ACT OF 1990
The Court of Common Pleas of Cumberland County is required by law to comply
with the Americans with Disabilities Act of 1990. For information about aceessible
facilities and reasonable accommodations available to disabled individuals havin9
business before the court, please contact our office. All arrangements must be made
at least 72 hours prior to any hearing or business before the court. You must
attend the scheduled eonference or hearing.
IIPR II Illli \:\ 195
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She is single.
The plaintiff currently resides with the following
persons:
H!m!
IRENE WOLFE
ROBERT WOLFE, JR.
HARLEY WOLFE
Relationl\lbiQ
daughter
son
son
The father of the children is ROBERT WOLFE, SR., currently
residing at 56 B Hall Kanor, Harrisburg, Pennsylvania.
He is single.
The defendant currently resides by himself.
16. The plaintiff has not previously participated in any
litigation concerning custody of the above mentioned children in
this or any other Court.
17. The plaintiff has no knowledge of any custody
proceedings concerning these children pending before a court in
this or any other jurisdiction.
18. The plaintiff does not know of any person not a party
to this action who has physical custody of the children or Claims
to have custody or visitation rights with respect to the
children.
19. Tho best interests and permanent welfare of the minor
children will be met if custody is temporarily granted to the
plaintiff pending a hearing in this matter for reasons including:
a. The plaintiff is a fit parent who can best take
care of the minor Children.
b. The defendant has shown by his abuse of the
(0-
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plaintiff that he is not an appropriate role model for
the minor children.
c. The defendant's behavior has adversely affected
the children.
WHEREFORE, pursuant to the provisions of the "Protection
from Abuse Act" of October 7, 1976, 23 P.S. S 6101 ~ ~., as
amended, the plaintiff prays this Honorable Court to grant the
fOllowing relief:
A. Grant a Temporary Order pursuant to the "Protection from
Abuse Act:"
1. ordering the defendant to refrain from abusing the
plaintiff and the minor children or placing them in fear of
abuse;
2. ordering the defendant to refrain from having any
direct or indirect contact with the plaintiff or the minor
children including, but not limited to, telephone and
written communications;
3. Ordering the defendant to refrain from harassing
and stalking the plaintiff and from harassing the
plaintiff's relatives;
4. Prohibiting the defendant from removing, damaging,
destroying or selling property jointly owned by the parties
or owned solely by the plaintiff;
5. ordering the defendant to stay away from any
residence the plaintiff has now or may establish for herself
in the future;
"
\
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The above-named plaintiff, DEBRA NORNHOLD, verifies that the
statements made in the above Petition are true and correct. The
plaintiff understands that false statements herein are made
subject to the penalties of 18 Pa. C.S. g 4904 relating to
unsworn falsification to authorities.
Date:
'2.- C(. 'I s"
i:J~k~ (t-1\,1\ ll6l11MJ
Debra Nornhold, Plaintiff
DEBRA NORNHOLD,
Plaintiff
for herself and on behalf
of her minor children:
IRENE WOLFE
ROBERT WOLFE, JR.
HARLEY WOLFE
vs.
ROBERT WOLFE, SR.,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 95-824 CIVIL TERM
PROTECTION FROM ABUSE
AND CUSTODY
PROTECTION ORDER
AND NOW, this 2x1~day of April, 1995, upon consideration
of the ,consent Agreement of the parties, the following Order is
entered:
1. The defendant, ROBERT WOLFE, SR., SS:UNKNOWN and DOB:
4/2/67, is enjoined from physically abusing the plaintiff, DEBRA
NORNHOLD, or the minor children, or from placing them in fear of
abuse.
2. The defendant is enjoined from having any direct or
indirect contact with the plaintiff including, but not limited
to, telephone and written communications, except for the limited
purpose of facilitating custody arrangements.
3. The defendant is ordered to refrain from harassing and
stalking the plaintiff and from harassing the plaintiff's
relatives.
4. The defendant is prohibited from entering the schools
of the children or the day care facilities of the minor children.
5. The defendant is ordered to stay away from the
plaintiff's residence located at Safe Harbour, 102 W. High
street, Carlisle, Cumberland County, pennsylvania.
6. The defendant is ordered to stay away from any
residence the plaintiff may in the future establish for herself.
7. The court costs and fees are waived.
B. This Order shall remain in effeet for a period of one
year or until modified or terminated by the Court after notice or
hearing and may be extended beyond that time if the Court finds
that the defendant has committed another act of abuse or has
engaged in a pattern or practice that indicates continued risk of
harm to the plaintiff.
9. This Order may subject the defendant to: i) arrest
under 23 Pa. C.S. 56113; ii) a private criminal complaint under
23 Pa. C.S. 56113.1; iii) a charge of indirect criminal contempt
under 23 Pa. C.S. 56114, punishable by imprisonment up to six
months and a fine of $100.00-$1,000.00; and iv) civil contempt
under 23 Pa. C.S. 56114.1. Resumption of co-residence on the
part of the plaintiff and defendant shall not nullify the
provisions of the court order.
10. The Carlisle police Departments shall be provided with
a certified copy of this Order by the plaintiff'S attorney and
may enforce this Order by arrest for indirect criminal contempt
without warrant upon probable cause that this Order has been
violated, whether or not the violation is committed in the
presence of the police officer. In the event that an arrest is
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,
DEBRA NORNHOLD,
Plaintiff
for herself and on behalf
of her minor children:
IRENE WOLFE
ROBERT WOLFE, JR.
HARLEY WOLFE
vs.
ROBERT WOLFE, SR.,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 95-824 CIVIL TERM
PROTECTION FROM ABUSE
: AND CUSTODY
AND NOW, this
TEMPORARY CUSTODY ORDER
l~ iL day of April, 1995, upon consideration
of the parties' Consent Agreement, the following temporary Order
is entered with regard to custody of the parties' children,
Irene, Robert, and Harley Wolfe.
1. The plaintiff, hereinafter referred to as the mother,
shall have physical and legal custody of the children.
2. The defendant, hereinafter referred to as the father,
shall have supervised visitation of the children every other
Saturday for two hours in the morning at a public place
supervised by Tammy Moore, at times and places to be mutually
agreed upon by the defendant and the plaintiff's sister, Tammy
.
Moore.
3. This Order shall remain in effect pending a concilation
conference.
4. Neither party shall do anything which may estrange the
children from the other parent, or injure the opinion of the
ehildren as to the other parent or which may hamper the free and
natural development of the children's love or respect for the
other parent.
By the Court,
~ U/. ~:' /
t.-:;> ~ A
J. esley Ole, r., jUd~e'
DEBRA NORNHOLD,
Plaintiff
for herself and on behalf
of her minor children:
IRENE WOLFE
ROBERT WOLFE, JR.
HARLEY WOLFE
vs.
ROBERT WOloFE, SR.,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 95-824 CIVIL TERM
PROTECTION FROM ABUSE
AND CUSTODY
CON8ENT AGREEMENT ,
_-I(t..!
This Agreement is entered on this cJ_1 day of April, 1995,
by the plaintiff, DEBRA NORNHOLD, and the defendant, ROBERT
WOLFE, SR. The plaintiff is represented by Joan carey of LEGAL
SERVICES, INC.; the defendant is unrepresented but is aware of
hie right to have an attorney. The parties agree that the
following may be entered as an Order of Court.
1. The defendant, ROBERT WOLFE, SR., agrees to refrain
from abusing the plaintiff, DEBRA NORNHOLD, or the minor
children, or placing them in fear of abuse.
2. The defendant agrees not to have any direct or indirect
contact with the plaintiff including, but not limited to,
telephone and written communications, except for the limited
purpose of facilitating custody arrangements.
3. The defendant agrees not to harass and stalk the
plaintiff and harass the plaintiff'S relatives.
4. The defendant agrees not to enter the schools or
daycare facilities of the minor ehildren.
5. The defendant agrees to stay away from the plaintiff'S
residence located at Safe Harbour, 102 W. High street, Carlisle,
cumberland County, Pennsylvania, which the parties have never
shared.
6. The defendant agrees to stay away from any residence
the plaintiff may in the future establish for herself.
7. The defendant, although entering into this Agreement,
does not admit the allegations made in the Petition.
B. The defendant understands that the Protection Order
entered in this matter shall be in effect for a period of one
year or until modified or terminated by the Court after notice or
hearing and, can be extended beyond that time, if the Court finds
that the defendant has committed another act of abuse or has
engaged in a pattern or practice that indicates continued risk of
harm to the plaintiff.
9. The defendant understands that this Order shall be
enforceable in the same manner as the Court's prior Temporary
Protection Order entered in this case.
15. The defendant and the plaintiff agree to the entry of a
Temporary Order providing for the following temporary custody
schedule for their children, Irene, Robert, and Harley Wolfe,
pending a concilition conference.
a. The mother shall have physical and legal custody
of the children.
b. The father shall have supervised visitation of the
children every other Saturday for two hours in the
morning at a public place supervised by Tammy Moore, at
times and places to be mutually agreed upon by the
defendant and the plaintiff's sister, Tammy Moore.
c. The parties realize that their children's well
being is paramount to any differences they might have
between themselves. Therefore, they agree that neither
party shall do anything which may estrange the children
from the other parent, or injura the opinion of the
children as to the other parent or which may hamper the
free and natural development of the children's love or
respect for the other parent.
WHEREFORE, the parties request that a Protection and
Temporary custody Order be entered to reflect the above terms.
~~~_lI~wJ
Debra Nornhold, Plaintiff
Pd~{[
Robert Wol
~<-
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'J. n Carey
. ttorney for Plain. ff
LEGAL SERVICES, INC.
a Irvine Row
Carlisle, PA 17013
(717) 243-9400
.
'.
DEBRA NORNHOLD,
Plaintiff
for herself and on behalf of her
minor ehildren: IRENE WOLFE, ROBERT
WOLFE, JR., HARLEY WOLFE
vs.
ROBERT J. WOLFE, SR.
Defendant
: IN THE COUR'r OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
.
.
.
.
NO. 95-824 CIVIL TERM
.
.
: IN CUSTODY
OOOER OF CXXJRT
AND OOW, this
of the attaehed Custody
directed as follows:
~ '-day of
Conciliation
, 1995, upon consideration
it ia hereby ordered and
~
Report,
1. The Mother, Debra Nornhold, shall have legal custody and primary
physieal eustody of Irene Wolfe, born May 30, 1990, Robert Nolfe, Jr., born
August 22, 1991 and Harley Wolfe, born March 25, 1993.
2. The Father, Robert J. Wolfe, Sr., shall have periods of supervised
visitation with the Children through the Supervised Visitation Program at
the YWCA in Carlisle, Pennsylvania. The soecific arrangements for the
supervised visitation shall be made through the YWCA Supervised Visitation
Program.
3. The Mother shall contaet the Father by telephone on a weekly basis
to enable the Father to speak with the Children.
4. The Mother shall notify the Father of any emergencies concerning
the Children and will provide the Father with eopies of report eards or
other progress reports regarding the Children I s development as well as
photographs of the Children. The exehange of these items shall occur
through the YWCA Supervised Visitation Program.
BY THE COURT0
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J.
cc:
Robert J. Wolfe, Sr. . .
Joan carey, Esquire Cirpu..1NJ...L.,.c
Sonya Hinkel, Paralegal
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DEBRA NORNHOLD,
Plaintiff
for herself and on behalf of her
minor ehildren: IRENE WOLFE, ROBERT
WOLFE, JR., HARLEY WOLFE
vs.
ROBERT J. WOLFE, SR.
Defendant
IN TilE COURT OF cc::ntON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
.
.
.
.
NO. 95-824 CIVIL TERM
:
: IN CUSTODY
CUSTOOY ~ILlATIOO SUMMl\RY REPORT
IN ACXXJRDANCE WITII aJ1IlERLAND WlNl"i RULE OF CIVIL PROCEDURE
1915.3-8, the undersigned CUstody Conciliator submits the following report:
1. The pertinent information pertaining to the Children who are the
subjects of this litigation is as follows:
NAME
BIRTHDATE
CURRENTLY IN CUSTODY OF
Irene Wolfe
May 30, 1990
MotherlPlaintiff
Mother/Plaintiff
Mother/plaintiff
Robert Wolfe, Jr.
August 22, 1991
Harley Wolfe
Mareh 25, 1993
2. A Conciliation Conference was held on April 25, 1995, with the
following individuals present:
A. The Mother, Debra Nornhold, with her eounsel, Joan Carey,
Esquire and Sonya Hinkel, Paralegal and the Father, Robert J.
Wolfe, Sr., who appeared without legal counsel.
3. The Mother's request for eustody of the parties' Children was
filed as part of a proteetion From Abuse Petition, alleging that the
Father's physical abuse of the Mother has adversely affected the Children.
The Mother, through eounsel, proposed superviSed visitat.ion at the YWCA in
Carlisle and the Father agreed to this restrietion on his periods of
partial custody with the Children.
4.
The parties agreed to entry of an Order in the form as attached.
(t<c I~(.v" dc"(!c
Dawn . Sunday, Custody 'oneiliator
Date
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