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CI;R'I'II'ICA'I'ION 01' PI'A'S
Case Number 1.5-1/3.1 ('u-d 7L'VH-.J
Name ~L...t: ,.f)M-,,:-, H~,J't--w-
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Victim's Name:
Cb,H.,,; ,1-1;:'
,~/..t."" 11'<-11,...12",)
Balance Due: $ 2s'CC
170 State Surcharge
171 State Fine
260 Sheriff Cost
ADD
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502 Restltut!.on
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ll/1.'1/'15
-
JENNIFER WINTERS,
petitioner
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO, 95-1133 CIVIL TERM
V.
JODY DEAN WINTERS,
Respondent
CIVIL ACTION - LAW
PROTECTION FROM ABUSE
NOTICE TO PETITIONER OR WITNESS:
IMMEDIATELY CALL THE POLICE
(911) IF THE RESPONDENT
VIOLATeS THIS PROTECTIVE ORDER.
_1/ h ORDER
AND NOW, this~ day of Apri 1, 1995, after a hearing on
this matter, it is HEREBY ORDERED AND DECREED as follows:
1. Respondent is prohibited from approaching, abusing,
threatening, or harassing Petitioner, either physically or
verbally, wherever she may be,
2. Respondent is prohibited from having any contact
with petitioner, except for matters concerning the visitation of
the parties' minor child, including entering or telephoning
Petitioner's home or place of employment,
3. Respondent is prohibited from stalking Petitioner as
that term is defined in the Crimes Code, 18 Pa, C.S, ~2709.
4.
of visitation
Respondent is
Respondent is prohibited from exercising his right
with the part ies' mi nor ch i Id un t i 1 said time as
psychologically evaluated,
5. The Prothonotary, Sheriff, and local law enforcement
agencies, are directed to accept, file and serve all copies of this
Order without prepayment of costs,
6. A certified copy of this order shall be served on
the Camp Hill Borough Police Department if said department is
wi thin the appropriate jurisdiction for Peti t ioner' s residence
and/or school or place of employment. Should the police come into
contact with Respondent, and should Respondent allege that he has
not been served with this Order, the police officer shall
immediately serve the Order upon him,
7.
agency in any
Section 10 (c)
This Order shall be enforced by any law enforcement
county where a violation occurs, As provided in
of the Act, "[aln arrest for violation of an order
, ~
issued pursuant to this act may be without warrant upon probable
cause whether or not the violation is committed in the presence of
the police officer,"
8. Respondent is hereby notified that if he violates
this Order, he may be held in indirect criminal contempt which is
punishable by a fine of up to $1000.00 and/or by a jail sentence of
up to six (6) months.
9. Respondent is hereby directed to pay Petitioner's
attorneys' fees in the amount of $250.
10, This Order shall remain in full force and effect for
a period of one year.
COURT:
J ,
DISTRIBUTION
Petitioner
Sheriff for Respondent
Cumberland County Court of Common Pleas
Camp Hill Borough Police Department
File
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JENNIFER WINTERS,
Petitioner
v.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO,
JODY DEAN WINTERS,
Respondent
CIVIL ACTION - LAW
PROTECTION FROM ABUSE
NOT ICE
YOU HAVE BEEN SUED IN COURT. If you wish to defend
against the claims set forth in the following pages, you must
appear at the hearing scheduled herein, You are warned that if you
fail to do so the case may proceed without you and an Order may be
entered against you for relief requested in the Petition. You may
lose money or property or other rights important to you,
If a copy of the
obey it until the hearing.
arrest you,
TEMPORARY ORDER is attached, you must
If you do not obey it, the pOlice can
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. YOU
HAVE A RIGHT TO HAVE AN ATTORNEY REPRESENT YOU AT THE HEARING, 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 MAY GET LEGAL
HELP.
COURT ADMINISTRATOR
4TH FLOOR, CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PA 17013
(717) 240-6200
V.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO, 9,,1/.33 C~':'f 71.,.___
CIVIL ACTION - LAW
PROTECTION FROM ABUSE
JENNIFER WINTERS,
Peti tioner
JODY DEAN WINTERS,
Respondent
NOTICE TO PETITIONER OR WITNESS:
IMMEDIATELY CALL THE POLICE
(911) IF THE RESPONDENT
VIOLATES THIS PROTECTIVE ORDER.
TEMPORARY PROTECTIVE ORDER
'-"'. 1
AND NOW. this f ,~K day of /ui.J..l.,~.&r
presentation and consideration of the within Petition,
ordered as follows:
, 1995, upon
it is hereby
1. Respondent is prohibited from approaching, abusing,
threatening, or harassing Petitioner, either physically or
verbally, wherever she may be,
2. Respondent is prohibited from having any contact
with petitioner, except for matters concerning the visitation of
the parties' minor child, includIng entering or telephoning
Petitioner's home or place of employment,
3. Respondent is prohibited from stalking Petitioner as
that term is defined in the CrImes Code, 18 Pa, C,S. 62709,
4.
of visitation
Respondent is
Respondent is prohibited from exercising his right
with the parties' minor child until said time as
psychologically evaluated.
5. The Prothonotary, Sheri ff, and local law enforcement
agencies, are directed to accept, file and serve all copies of this
Petition and Order without prepayment of costs.
6, A certified copy of this Order shall be served on
the Camp Hill Borough Police Department if said department is
within the appropriate Jurisdiction for Petitioner's residence
and/or school or place of employment, Should the police come into
contact with Respondent, and should Respondent allege that he has
not been served with this Order, the police officer shall
immediately serve the Order upon him.
7. This Order shall be enforced by any law enforcement
agency in any county where a violation occurs. As provided in
Section 10 lc) of the Act. "laIn arrest for violation of an order
issued pursuant to this act may be without warrant upon probable
,.
cause whether or not the violation Is committed in the presence of
the police officer."
8, Respondent Is hereby notified that if he violates
this Order, he may be held in indirect criminal contempt which is
punishable by a fine of up to $1000.00 and/or by a Jail sentence of
up to six (6) months,
9. This Order shall remain in full force and effect
until further Order of the Court.
~.10, a hearing on this matter is scheduled for the /~fkJ
dayof---I..r..1U~0 ,1995, at 1.;'.7' /:30, .L.M.,
in Court Room No. ~l Cumberland County Courthouse, One
Courthouse Square, Carlisle, PennsYlvania.
BY THE COURT:
DISTRIBUTION
Petitioner
Sheriff for Respondent
Cumberland County Court of Common Pleas
Camp Hill Borough Police Department
File
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JENNIFER WINTERS,
Petitioner
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO, 'h~ 113~ Cu.~ 'r<V"'"\
CIVIL ACTION - LAW
PROTECTION FROM ABUSE
V.
JODY DEAN WINTERS,
Respondent
PETITION FOR PROTECTION FROM ABUSE
TO THE HONORABLE JUDOES OF SAID COURT:
AND NOW COMES the Petitioner, Jennifer Winters, by and
through her attorney, Kristin R, Reinhold, Esquire, pursuant to the
Protection from Abuse Act, 23 Pa,C,S, 666101, .!ti-~.. as amended,
and respectfully represents the following:
.,
1. Petitioner is Jennifer Winters, an adult individual
presently residing at 1919 Princeton Avenue, Camp Hill, Cumberland
County, Pennsylvania. 17011.
2. Respondent Is Jody Dean Winters whose last known
residence was a psychiatric hospital, Columbine Center: 8565 South
West Poplar Way. Littleton, Colorado. 80126.
3. The relationship between Petitioner and Respondent
is that of Wife and Husband.
4. Petitioner is employed at Capital Blue Cross, with
approximate gross earnings of $28,000.00 annually,
5, Respondent's employment is unknown to the Petitioner
at the present time,
6, petitioner is the sole and exclusive owner of the
real estate located at 1919 Princeton Avenue, Camp Hill, Cumberland
County, pennsylvania, and Respondent has no interest therein.
7, Pet! t ioner and Respondent are the natural parents of
the following minor chi ld:
Jared E, Winters, born February 12,
1991,
8. Respondent is diagnosed with a bi-polar disorder and
has been hospitalized for the past few months in two psychiatric
hospitals. Respondent was released from Columbine Center, located
in Littleton colorado, approximately one month ago.
Petitioner
believes, based upon Respondent's erratic and threatening behavior
that Respondent is not taking his medication which controls his bi-
polar disorder,
9, Respondent has engaged in abusive conduct towards
the Petitioner as such conduct is defined in the Act, Examples of
said conduct include, but are not limited to, the following:
a. On or about February 13, 1995, Respondent
called the Petitioner and told her how much he hated her and
threatened to come back to Pennsylvania to get his son.
b, On or about January 30, 1995, Respondent
contacted Petitioner's mother at 3:00 A.M, to tell her how
much he hated the Petitioner.
c, On or about January
contacted Petitioner's mother at her
how much he hated the Petitioner,
d, In October, 1994, Respondent came to the
parties: home. and accused Petitioner of numerous incidents of
wrongdoing, Including infidelity. Respondent pushed the
Petitioner and attempted to drag her out of the house
forcibly, Respondent threatened the Petitioner's safety.
25, 1995, Respondent
employment to tell her
Petitioner attempted to contact 911 for help but Respondent
blocked her access to the telephone for several minutes.
Eventually, Petitioner was able to contact 911 for help, This
incident occurred in the presence of the parties' 3 1/2 year
old son,
e. There have been numerous other incidents in the
past where Respondent has treated Petitioner abusively to one
degree or another, including punching her. giving her a black
eye, pushing her, and threatening her.
10. Petitioner believes that she is in immediate and
present danger of further abuse and harassment from Respondent, and
that she is in need of, and enti tied to, protection from such
abuse,
11. Petitioner and Respondent entered into a Custody
Stipulation, docket number 94-6493 in December of 1994, Petitioner
now believes that Respondent is a danger to the parties' child. A
copy of said stipulation, marked Exhibit "An is attached hereto and
incorporated herein,
12. Petitioner believes and therefore avers that it is
in her child's best interests and welfare that Respondent be
prohibited from seeing the parties' child until said time as
Respondent can be psychologically evaluated.
WHEREFORE, pursuant to the Protection from Abuse Act,
Petitioner prays your Honorable Court to:
I. Immediately enter a temporary order, pursuant to Section
5 (b) of the Act, 23 Pa. C,S, !l6107 (b);
A. Directing Respondent to refrain from approaching,
abusing, harassing, or threatening Petitioner, either physically or
verbally, wherever she may be;
8. Excluding Respondent from any rcsidcncc which
Petitioner or the minor child may occupy whilc this Order rcmains
in effect;
C, Prohibiting Respondent from contacting Petitioner,
including entcring or telephoning Petitioner's home or place of
employment;
D. Prohibiting Respondent from stalking Petitioner as
that term is defined in the Crimes Code, 18 Pa. C,S. ~2709; and
E. Prohibit Respondent from exercising his right of
visitation with the parties' minor child until said time as
Respondent is psychologically evaiuated,
II. After the hearing, and pursuant to Section I of the Act, 23
Pa. C,S. ~6108, enter a final protection order continuing the
relief set forth above, for a period of one (I) year, and further
requiring that Respondent:
A, Pursuant to Section 5(d) of the Act, 23 Pa. C,S.
~6107(d), pay all taxable costs of this action;
B. Pay Petitioner's attorneys fees in the amount of
$250.00;
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C, Any other rei ief this Honorable Court deems
reasonable and Just,
I
DATE:
::1/:11 JCJ"-I
1/, oX
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SILL KER & REINHOLD
204 State Street
Ha rlsburg, PA 17101
(717) 233-1000
I.D. No.: 57911
Attorney for Petitioner
.
v,
IN TilE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. ql/- ({I{/q 3 Civillevm
CIVIL ACTION - LAW
CHILD CUSTODY
JENNIFER WINTERS,
Plaintiff
JODY DEAN WINTERS,
Defendant
,STIPULATION
The undersigned parties to this agreement, Plaintiff
JENNI FER WI NTERS, and Defendan t JODY DEAN WI NTERS I hav ing fully
consulted on this matter, HEREBY AGREE TO THE FOLLOWING:
1, Plaintiff Jennifer Winters shail have primary legal
and physical custody of the subject minor child, Jared C, Winters,
born February 12, 1991',
2, Defendant Jody Dean Winters shall be entitled to
partial periods of physical custody, for purposes of visitation,
consist ing of:
a. Father shall be entitled to every other
weekend, shared holiduys, two (2) non-consecutive weeks during
the summer vacation, and other times to be agreed upon between
the paJ.t ies.
~f;:
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JODY DEAN W NTERS
Dated:-1'J ' II../...-CYLf
Dated:
/7----C -1'1
Exhibit "A"
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STATE or PENNSYLVANIA
'!
SS:
COUNTY or CUMBERLAND
b.... (/
On this ~<'l day of ,<,-'''(.":_",,A.;~ ) ,1994, before
me Subscri bel', a Notary Public, for the Commonweal th of
Pennsylvania, came Jennifer Winters. known to me or satisfactorily
proven to be the Defendant in the afore O~g StiPulati~_
J nnl er Winters
I,
'I
WI tness my hand and
aforesaid,
seal, the day and year
'L) b--v-.-<.~ /J ' ~"'-1
Notary ,Public
My Commission Expires: tJ'l/;!..",-j;'J17
STATE or PENNSYLVANIA
SS:
COUNTY or CUMBERLAND
(JHM",'/tJ On this r;;1f,- ~aY of Y..<tC Il-,h--r: , 1994. before Ar,,"
me subscriber. a Notary Public, for the eemmon..",..lth nEfL""'6
Pennsyl"aRia, came Jody Dean Winters, known to e or satisfactorilY
proven Lo be the Plaintiff in the af eg I g t'
witness my hand and Notarial
aforesaid,
seal.
the
and year
J/lAA-e" , 0,
( Nota Y Public
My Commission Expires:
A F F I D A V I T
I, ~,J')f)n\rer \()\"krs, hereby certify that the
aforegoing is true and correct to the best of my knowledge,
information and belief. I understand that false statements
herein are made subject to the penalties of 19 Pa. C.S. 4904
relating to unsworn falsification to authorities.
Da ted : Cl /..)c~: / q5
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1l^ItUIS1HtIHlll't~....sn-\'^~I^ 171111
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JENNIFER WINTERS,
Petitioner
v.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
No. 95-1133 civil Term
CIVIL ACTIOn - LAW
PROTECTION FROM ABUSE
JODY DEAN WINTERS
Respondent
AND NOW,
this {S ~y of
, 1995, upon
by agreement of the
consideration of the request 0
parties, IT IS HEREBY ORDERED, that the hearing previously
scheduled for March 10, 1995, at 1:30 p.m. is continued until
April 24, 1995, at 10:00 a.m. and, IT IS FURTHER ORDERED that the
Temporary Protective Order dated March 1, 1995 shall remain in
effect until April 24, 1995.
J.
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DRUCe D. BAOlt'l'
ltRRY R. DO$5UfT
ALANR.8O'tNTON.JR
tIIOCC""""""
AOOtm M. CHtRR1
INlLl.W4;". CHDNun
DAVID D. DlSHt'I'
MICHALLA DOCTRON
tuZl+.DCTH A. OOUCoHtRlY
HI+.RVtV 'Rtt<<NDtRO
.JNoIUL.'RlTt
'RN+C15 B. HAAS. JR.
W.JurRVJAJolOUNt.AU
MICHI+.tI.O.JARMAN
DAVlDIol.~NGtR
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rRANIWN;" MILts. JR.
RQ6[RT;". MILLS
STtPHtNA MOORe
"tROCRT R. HURtCt(
JOHHIS.QYl.tR
lIkOIHYJ. prlSTtR
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tDWAAOW. ROTHMAN
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ROB[RT D. ISTtTS
R1CHAADW.STtvtN5ON
OIAHt M. T~RSKY
McNEES, WALLACE & NURICK
ATTORN~S AT LAW
100 PINE: SlREE:T
P. O. DOX lIe6
HARRISBURG, PA 17108'1188
TtU:PHONCI7171232'8QOO
FAXI71712J7'5300
DAVlDM.WAJTS.JR,
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NrAl.l5.W[.5T
HOJfMAN I. WHITt
LJ'WR[ Net R. W1totR
GAR"l".ytN~
INlLUAMM.'tOJHO.,m
OFCOUN'"AL
ROOtRT H. QAI5'MJLD
6NolUCL ^ r.ctlRt.CIttNGMJ5T. JR
tAlC "'.I+.THt'I'
DAVID M. QAXER
JONATHl+.NC. DtRRY
DRtTT D. DAVIS
JAMU P. DcANGtLO
JAMES P. QOUGHtR'TY
AATHL[tN;". DuNST
ROQ[RT J.OOOUTD
April 20, 1995
The Honorable George E. Hoffer
Cumberland County Courthouse
1 Courthouse Square
Carlisle, PA 17013
~
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Re: Winters v. Wint
C.P. Cumberlan
Dear Judge Hoffer:
SCOTT ;", GOUlD
P. NICHOlA!IOUAANUCHtW
PODtRf O. HM9
ORII+.N ,.. JACKSON
OOt'V<I.DD.AAU'~
~ICHAt.l. R.IttLLEY
peTtR" ."""Ot
JAMES W.I<UTZ
CN-IILU C.IoWftON
P"TRlCKJ.~URPHY
5HARON A. PAXTON
CHUQNQH.PHAM
JONATHAHH.RUDD
DRUCe A. 5PlCUI
CAAQL.A.I$TClNOUR
CATHtAlN[t.WI+.LTtR5
IXllRICK P. W1L1JNootSOH
We have been unable to reach an agreement with Jody Dean
Winters regarding our continued representation of his interests
in this matter. Accordingly, McNees, Wallace & Nurick no longer
represents Mr. Winters. Although we have not previously entered
our appearance in this matter, we felt that it was appropriate to
inform the Court at this time that we will not be representing
M ' be attending the PFA hearing scheduled
By copy of this letter, we are
R. Reinhold, who represents Jennifer
represent Mr. Winters.
Respectfully,
McNEES, WALLACE & NURICK
~p. ~(~
By - 0 ,~___
James P. DeAngelo
JPD/mca
cc: Kristin R. Reinhold, Esquire
Mr. Jody Dean Winters
. ..
,
RUBY I, GEHR,
Plointi ff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
95-1113 CIVIL TERM
V,
GERALD R, GEHR,
Defendont
IN....B8-lNll.IREU-lJUJ1l.NALl01UE11.e.T.
PFA ORDER-EXIENllED,
ORllElLQLUURI
AND NOW, October 9, 1997, 11:20 o,m" Gerald R, Gehr,
having appeared in open court together with personal counsel,
Ruby D, Weeks, Esquire, and the defendant having appeored on a
petition alleging indirect criminal contempt of our PFA Order of
November 18, 1996, and the defendont hoving admitted the
allegotions of the petition, we do find the petition to be
supported beyond a reosonoble doubt and we do find the defendont
to be in contempt of court,
Upon the recommendotion of the District Attorney thot
the court impose 0 probotionory sentence, ond with the
concurrence of the victim in the case in that recommendation,
"
sentence of the court is that the defendont shall be placed on
probation for a period of six months with supervision by the
Probation Office, on the condition that the defendont abide by
the prior PFA Order, that he pay ony costs of prosecution
associated with this contempt petition, and thot he continue
with his counseling at the Helen Stevens Center, os mondated by
PPG, his employer, os a condition of his retaining employment,
The supervision will be primarily to insure that the defendant
continues with the Helen Steven's counseling,
The defendant will be given three months to pay any
. ~
~
95-1113 Civil Term
In He: PFII
Page 2
costs associated Hith this motter,
At the request of the District IIttorney, He extend the
benefit and the full force and effect of our PFA Order dated
November 18. 1996. for twelve months from this dote,
II copy of this order will he sent to the Carlisle
Police Deportment,
Uy tlw Court.
Ge-o,:ge _u,_ - , - -
Michoel $, SChHoyer. Esquire
Chief Deputy District IIttorney
One Courthouse SQuore
Corllsl\!. 1'0, 17013
For the COlllmonwealth
Ruby II, Weeks. ESQulr\!
10 Wes t tHuh Str\!ot
Curlls1e. 1'0, 17013
For the De fomJun t
Leunl SI!,.vtCI1~. Inr.,
B lrvtrlll flOH
CnrJisl\!. 1'0, 17013
For tho Plntnttrr
Curllsle Pollcl' Ilepnrlllwnt
53 Hest South street
Cnrllsl!', Pu, li'013
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V.
IN TilE COUIlT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVAN I A
NO, c,) 113, ('1:L\ 7;".~"
JENNIFEIl WINTERS.
Petitioner
JODY DEAN WINTERS,
Respondent
CIVIL ACTION - LAW
PROTECTION FROM ABUSE
NOTICE TO PETITIONER OR WITNESS:
IMMEDIATELY CALI. TilE POLICE
(911) IF TilE RESPONDENT
VIOLATES TillS PROTECTIVE ORDER.
'J'.1lMPQ.R~RL !.'.RQJ:.~G,.'t-L'!'JLQRP_E.R
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AND NOW, this y" day of NI.I,d/:.o--
presentation and consideration of the within Petition.
ordered as follows:
, 1995, upon
it is hereby
1, Respondent is prohibited from approaching, abusing,
threatening, or harassing Petitioner, either physically or
verbally, wherever she may be.
2. Respondent is prohibited from having any contact
with petitioner. except for matters concerning the visitation of
the parties' minor child. including entering or telephoning
Petitioner's home or place of employment,
3, Respondent is prohibited from stalking Petitioner as
that term is defined in the Crimes Code. 18 Pa. C.S, 62709.
4.
of visitation
Respondent is
Respondent is prohibited from exercising his right
with the parties' minor child until said time as
psychologically evaluated.
5, The Prothonotary, Sheriff, and local law enforcement
agencies, are directed to accept. file and serve all copies of this
Petition and Order without prepayment of costs,
6. A certified copy of this Order shall be served on
the Camp Hi 11 Dorough Pol ice Department if said department is
within the appropriate jurisdiction for Petitioner's residence
and/or school or place of employment. Should the police come into
contact with Respondent, and should Respondent allege that he has
not been served wi th this order, the police officer shall
immediately serve the Order upon him,
7, This Order shal I be enforced by any law enforcement
agency in any county where a violation occurs, As provided in
Section 10 (c) of the Act, "llIln lIrrest for violation of an order
issued pursullnt to this nct mllY be without wllrrnnt upon probable
,;
cause whether or not the violation is committed in the presence of
the police officer,"
8. Ilespondent is hereby not i fled that if he violates
this order. he may be held In Indirect criminal contempt which Is
punishable by a fine of up to $1000,00 and/or by a jai 1 sentence of
up to six (6) months,
9. This Order shall remain in full force and effect
until further Order of the Court,
~,IO, a hearing on this matter is scheduled for the LlJ'~
day of __Li~1J.J.L' . 1995, at """~ 1,10 . __,4I_~
in Court Room No,..! Cumberland County Courthouse, One
Courthouse Square. Carlisle, Pennsylvania,
BY THE COURT:
J.
DI STRI BUTION
Pet i tioner
Sheriff for Respondent
Cumberland County Court of Common Pleas
Camp Hill Borough Police Department
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