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JACR RUSSELL KNIPE, III,
Plaintiff
1 IN THE COURT OF COMMON PLEAS OF
1
: CUMBERLAND COUNTY, PENNSYLVANIA
I
I CIVIL ACTION - LAW
I
I NO. 95-3106 CIVIL TERM
1
1 PROTECTION FROM ABUSE
v.
BHANA LYNN PENNER,
Defendant
ORDER FOR CONTINUANCE
AND NOW, this ~day of June, 1995, upon defendant's
request for a continuance and plaintiff's counsel's agreement to
ft continuance, the hearing echeduled for June 19, 1995, at 1130
p.m. in Courtroom No.5, is continued until
(,~. {"',, / 7
, .-"
, 1995
at '7.1.\;
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~.m. to afford ths defendant time to obtain ~ b2n2
referral counsel through Legal Services, Inc..
The Temporary
Protective Order will remain in effect pending further order of
court.
By the Court,
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: IN THE COURT OF COMMON PLEAS OF
: CUM8E1U.AND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
; NO, 95- ~I(t-CIVIL TERM
: 1)ltoTECTION FROM ABUSE
JACK RUSSELL KNIPE III,
Plaintiff
SHANA LYNNE PENNER,
Defendllnt
INSTRUCTIONS TO THE DEFENDANT
As you know, the Plaintiff has flied a legal action against you under the Protection
From Abuse Act IInd has obtained a Temporary Protection Order. The Plaintiff is prepared
to have a hearing held in order to obtain a final Protection Order effective for one (1) year.
As an alternative, you may consent to the entry of the final Protection Order to be in
effect for one year, If you are willing to consent you should call Plaintiff's counsel, Paul
Bradford Orr, Esquire, in Carlisle at 258-8558.
The Consent Agreement should be prepared before the time scheduled for the hearing
so the Court will know ahead of time that the case will not be contested. 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 uncontested. the court
appearance will be brief. The judge will make sure the parties understand the Consent
Agreement and final Protection Order,
If you do not agree to the entry of the final Protection Order, a contested hearing wlll
take place at the scheduled time. When a final Protection Order is entered, it will be sent or
given to you, the Plaintiff, and the appropriate police departments, If you fail to abide by the
terms of the final Protection Order you will be subject to Immediate arrest, and a fine of
$100.00 to $1,000,00 and/or a jail sentence of up to six months and other relief.
FEES AND COSTS
If the case goes to hcaring and the judge grants a Protection Order, a surcharge of
$25.00 will be assessed against yon,
YOU SHOULD TAKE THIS PAPEI\ TO YOUR LAWYER AT ONCE, IF YOU
DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE. GO TO OR
TELEPHONE TIlE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU
CAN GET LEGAL HELP.
Court Administrator. Fonrth Floor
Cumbcrland County Court House
I Courthouse Square
Carlisle.PA 17013
Phone: (717) 240.6200
JACK RUSSELL KNIPE III,
Plalnliff
: IN TIlE COURT 01' COMMON PLEAS OF
: CUMBERLAND COUNTY,I'ENNSYLVANIA
v.
.
: CIVIL ACTION. LAW
, 301~
: NO. 95- CIVIL TERM
: PROTECTION FROM ABUSE
SHANA LYNNE l'ENNEn,
Dcfcndanl
TEMPORARY PROTECI'ION ORDER
AND NOW, Ihis ~ day of Junc, 1995, upon prcsenlationand consideration of
the within Petilion, and upon finding Ihal the Plaintiff, Jack Russcll Knipe III, now residing
at 1354 Caboose Lanc, Boiling Springs, Cumberland County, I'ennsylvania, Is in immediate and
present danger of abuse from the Defendant, Shana Lynne Penner, the following Temporary
Order is entered,
The Defendant, Shana Lynne Penner, (SSN Unknown and DOB Unknown) Is last
known to be residing at 564 Mountain Road, Boiling Springs, Cumberland County,
Pennsylvania, 17007, is hereby enjoined from physically abusing the Plaintiff, Jack Russell
Knipe III, or placing him in fear of abuse.
The Defendant is ordered to stay away from the Plaintiff's residence located at 1354
Caboose Lane, Dolling Springs, Cumberland County, Pennsylvania, a residence which Is owned
by the Plaintiff's Mother and Father,
The Defendant Is ordered to refrain from having any direct or indirect contact with
the Plaintiff Including, but not limited to, lelephone, wrlllen communications, and paging
devices.
The Defendant Is cnJoined from hafllsslng and stalking the Plainllff and from haflllSlng
the Plaintiff's relatives and associates.
The Defcndant is enjoined from enlering thc Plainliff's placc of employment.
^ violation of this Order may subject the Defendant to: I) IIrrest under 23 Pa. C.S,
~6113i 2) a private criminal cOlllplllint under 23 I'a. C.S. ~ 6113.1; 3) a charge of Indirect
criminal contempt under 23 I'a. C.S, ~ 6114, punlshllble by imprisonment up to six months and
a rine of $100.00 to $1,000.00; and 4) civil contempt under 23 Pa. C,S. ~ 6114,\, Resumption
of co-residence on the part of the 1'IIIIntlff 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 and, clln 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.
This Order shall remain in effect untltmodlfled or terminated by the Court after notice
or hearing, A hearing shall be held on the /f/li. day of I ):0'-".---1 1995, at
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. Cumberhllld County Court House,
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,
Carlisle, Pennsylvania,
This Order shall be docketed in the office of the Prothonotary and forwarded to the
Sheriff for selVice. The Prothonotary shall not send a copy of this Order to the Defendant by
mail.
The Pennsylvania State I'olice allllthe Carlisle Police Department wlll be provided with
certified copies of this Order by the l'lalnliff's attorney, This Order shall be enforced by any
hlw enforcement agency where n violation occurs by arrest for indirect criminal contempt
without warrant IIpon probllble calise that tbls Order hilS been violated, whether or not the
violation is committed in the presence of the police officer. In the event that an arre.t I.
made, IInder this sel'lion, the Defendllnt shllll be taken wlthoutllnnecessary delay before the
Court that Issued the order. When that COllrt is unavailable, the Defendant shall be taken
before the appropriate district justice. (23 I'a, c.s, ~ 6113),
By the Court:
JACK RUSSELL KNIPE III,
Plaintiff
: IN TIlE COUIn OF COMMON PLEAS OF
: CUMBEI\LAND COUNTY, PENNSYLVANIA
v,
.
: CIVIL ACTION - LAW
: ,V'"-
: NO. 95. I CIVIL TERM
: IN PROTECTION FIWM ABUSE
SHANA LYNNE PENNER,
Defendant
PETITION FOR PROTECTION ORDER
RELIEF UNDER THE PROTECTION FROM ABUSE
ACT, 23 P,S. ~ 6101 ET SEQ.
A. ABUSE
\. Plaintiff is JACK RUSSELL KNIPE III, an adult individual currently residing at
1354 Caboose Lane, Boiling Springs, Cumberland County, Pennsylvania, 17013.
2, Defendant is SHANA LYNNE PENNER, an adult Individual who currently resides
at 564 Mountain Road, Boiling Springs, Cumberland County, Pennsylvania, 17007.
3, Since approximately March 29, 1995, the Defendant has attempted to cause and has
intentionally, knowingly, or recklessly caused bodily injury to the Plaintiff, or has placed the
Plaintiff In reasonable fear of imminent serious bodily injury, and has knowingly engaged in
a course of conduct or repeatedly committed acts toward the Plaintiff under circumstances
which have placed the Plaintiff in reasonable fear of bodily injury. This has included, but is
not limited to, the following specific instances of abuse:
A. On or about March 29, 1995, Defendant paged the l'laintlff requesting a
meeting. 1'llIintiff refused to comply.
B. On or about April 3, 1995, Defendant repeatedly paged Plaintiff at times
including but not limited to I :45 p.m., 2:50 p.m., and 9:50 p.m, Plaintiff refused to
respond.
C. On or about April 12, 1995, Dcfcndant telcphoncd l'laintiff at home at
approximatcly 4:30 p.m. rcqucsting a mccting. Plaintiff again rcfuscd.
D, On or about April 17, 1995, Dcfcndant tclcphoncd Plaintiff at homc, became
hystcrical, and dcmandcd a mccting with Plaintiff. Plaintiff rcfuscd,
E. On or about April 18, 1995, Dcfcndant and fricnds of Defcndant called and
thrcatened Plaintiff regarding previous allcgcd incidcnts, Thc words of thc Defendant
and friends of the Defendant wcrc "If Plaintiff docs not go to jail, thcn they will take
matters into their own hands."
F. On or about April 20, 1995, Defendant tclcphoned Plaintiff at home
requcstlng 01 mccting at a ncarby location. Plaintiff rcfused to meet Defendant.
G. On or about April 27, 1995, Defendant made rcpeated telephone calls to
Plaintiff's home.
H. On or about May 2, 1995, Defendant telcphoned Plaintiff at his residence
wanting again to meet with Plaintiff. Plaintiff rcfused to comply,
I. On or about May 8, 1995, Dcfcndant made rcpeatcd tclephone calls to
Plaintiff's home,
J. On or about May 9, 1995, Defcndant made repeated telephone calls to
Plaintiff at home.
K, On or about May II, 1995, Defendant telephoned Plaintiff at home,
L, On or about May 12, 1995, Defendant and Defendant's sister "Haven"
rcpeatedly drove by Plaintiff's house in a white Ilyundal beginning at approximately 6:30
p.m. and ending sometime later that cvenlng.
M. 011 or Rbout MRY 14, 1995, DefendRnt repeRtedly telepboned 1'lRIntiff Rt his
house once RgRln Rtlemptlng to lure the 1'lRlntiff into meeting with DefendRnt. I'lalntiff
refused,
N, On or about May 19, 1995, while l'lalntlff Rnd I'lalntlff's girlfriend were
stopped Intrnffic In North Middleton Township, DefendRnt rRn towRrds I'IRlntiff's car
screaming Rnd yelling In R hysterlcalmRnner, Rnd used numerous profanities directed
towards the I'lalntlff,
0, 011 or about May 22, 1995, Defendant drove repeatedly by I'lalntlff's house
honking the horn Rnd cRuslng a general disturbance In the neighborhood.
I'. On or about May 23, 1995, Defendant repeatedly paged I'laintiff; telephoned
I'lalntlff at his residence, and requested him to meet her neRr I'lalntiff's house. Plaintiff
again refused to comply with Defendant's luring demands.
Q. On or Rbout May 25, 1995, DefendAnt drove up In front of Plaintiffs hOUle,
stopped and honked the horn repeatedly,
R. On or about MRY 29, 1995, Defendllnt called Rnd left threatenln. mega.e.
on I'lalntiff's answering machine at his residence.
S, On or About June 6, 1995, Defendant without Any rellson to be In the
neighborhood, Appeared At 157 College Park ^partments where I'lalntiff wa. witch in,
television. DefendRnt begRn IIctlng In Rn Irrlltional and hysterical manner for no
legitimate reRson.
T. Since MRrch 22, 1995, DcfendRnt has rcpeatedly threatened to have bodily
hRrm cRused to the PIRlnliff, apparently bRsed on some false delusion that Plaintiff I.
the father of her unbnrnl'llild.
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4. Plaintiff believes and therefore avcrs that hc is In irnmcdlatc and present danger of
physical and mental abuse frolll the Defendant, and that he Is In need of protection from such
abuse.
5. Plaintiff desires that the Defendant be prohibited from having any direct or Indirect
contact with the Plaintiff including, but not limited to, telephone and written communications.
6. Plaintiff desires thAt the Defendant be enjoined from hArAssing And stalking the
Plaintiff, and from harassing the PlAintiffs relAtives,
7. Plaintiff desires that the Defendant be restrained frolll entering his place of
employment.
B. ATIORNEY FEES
8, Plaintiff asks that the Defendant be ordered to pay reAsonable Attorney fees to Paul
Bradford On, Esquire.
WHEREFORE, pursuAnt to the provisions of the "Protection From Abuse Act" of
October 7, 1976,23 P,S. ~ 6101, tlH!I., as amended, the PlAintiff prAYs this Honorable Court
to grant the following relief:
A. Gmnt a Temporary Order pursuant to the "Protection From Abuse Act:"
I. Ordering Defendant to refrain from abusing the Plaintiff or placing
Plaintiff In fear of Abuse;
2. Ordering Defendant to refrain from having any direct or Indirect contact
with the Plaintiff including, but not limited to, telephone and written
communications;
3, Ordering the Defendant to refrain frolll harassing and stalking the PlAintiff
and frum harassing the I'laintiff's relatives;
4, Prohibiting thc Defendllnt from cntering the Plllintiff's place of
employment;
5. Ordering the Defendant to stay away from the Plaintiff's residence located
at 1354 Caboose Lane, UollingSprings, CumberlllndCounty, Pennsylvania,
which the parties have never shared;
6, Ordering the Defendant to stay away from any residence the Plaintiff may
In the future establish,
8, 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 Defendant to refrain from abusing the Plaintiff or placlnB
Plaintiff in fear of abuse;
2, Ordering Defendant to refrain from having any direct or Indirect contact
with the Plaintiff including, but not limited to, telephone and written
cOlllmunications;
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 l'lalntlff's place of
employment;
5. Ordering the Defendant to stay away from the Plaintiff's residence located
at 1354 Caboose I.llne, Bolling Springs, r':umberlllnd County,Pennsylvanla,
which the parties have never shllred;
6. Ordering the Defendant to stay IIwllY frolllllny residence the Plllintlff may
in the future estahlish.
7, Ordering the Defendant to pay reasonable attorney fees to Paul Bradford
Orr, Esquire,
The Plaintiff further asks that certified copies of this Petition and Order be delivered
to the Pennsylvania State Police and Carlisle Police Department who have jurisdiction to
enforce this Order,
The Plaintiff prays for such other relief as may be just and proper,
Paul Bradford rr, Esq.
Attorney for Plaintiff
78 W, Pomfret Street
Carlisle, PA 17013
(717) 258.8558
'nle above-named Plaintiff, JACK IWSSELL KNIPE III, verifies that the statements
made in the above Petition arc true and correct, Plaintiff understands that false statements
herein are made subject to thl' penalties of 18 "a.C.S. 6 4904, relating to unsworn falsification
to authorities.
Date: .(.Ill}
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/ Jac Russell Knipe III, Plaintiff
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.----;-.,.
I II _
JACK RUSSELL KNIPE III.
Plaintiff
v.
SHANA LYNNE PENNER,
Defendant
ORDI<;R 010' COURT
: IN TIlE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION. I.A W
: NO, 95.3106 CIVIL TERM
: PROTECTION FROM ABUSE
AND NOW, this b k day of September. 1995, upon Plaintiff's Motion to
Withdraw, it Is hereby ordered that Plaintiff's Protection From Abuse action filed to captioned
number and term is hereby withdrawn,
BY THE COURT://
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JACK RUSSELL KNIPE III,
Plaintiff
: IN TilE couln OF COMMON PLEAS OF
: CUMIlERLAND COUNTY, PENNSYLVANIA
v,
,
: CIVIL ACTION - LAW
: NO, 95-3106 CIVIL TERM
: PROTECfION FROM AIlUSE
SHANA LYNNE PENNER,
Defendant
MOTION TO WITHDRAW
Plaintiff, JACK RUSSELL KNIPE III, by and through his Attorney, Paul Bradford
Orr, Esquire, respectfully requests this Honorable Court to withdraw his previously filed
Protection From Abuse action against captioned Defendant, SHANA LYNNE PENNER.
Date: 9 b q(
'''p'' :IJhmlll" V
ul Bradford 0 r, Esq.
Attorney for Plaintiff
78 W. Pomfret Street
Carlisle, PA 17013
(717) 258-8558
-.
JACK RUSSELL KNIPE, III,
plaintiff
v.
SHANA LYNN PENNER,
Defendant
I
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 95-3l06 CIVIL TERM
ORDER OF COURT
AND NOW, this (, ~ day of July, 1995, upon consideration of
the attached letter from Andrea C. Jacobsen, Esq., attorney for
Defendant, the hearing previously scheduled in this matter for July
17, 1995, is RESCHEDULED to Wednesday, September 6, 1995, at 9100
a.m., in Courtroom No.5, cumberland County Courthouse, Carlisle,
Pennsylvania.
The Temporary Protective Order of June 9, 1995, will remain in
full force and effeot pending further Order of Court.
BY THE COURT,
Paul B. Orr, Esq.
78 West Pomfret Street
Carlisle, PA l7013
Attorney for Plaintiff
Andrea C. Jacobsen, Esq.
52 East High Street
Carlisle, PA l70l3
Attorney for Defendant
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Samucl W, Mllkcs
AndrclI C, Jllcobscn
JACOBSEN & MILKES
52 Ellsl IUgh SlrL'cl
Carlislc,l'A 17013.30H5
Tcl 717 249.6427
Fux 717 249.11427
June 21, 1005
Honorable J, Wesley Oler
Cumberland County Courthouse
1 Courthouse Square
Carlisle, PA 17013
ReI Knipe II. Penner, Protection From AbUH
Dear Judge Oler:
This is to confirm my telephone call of this afternoon with Ruth.
I expect to be representing Shana Penner in the Protection From Abuse action
rued against her by Jack Russell Knipe, III, I have been advised by Legal Services that
a hearing on the petition originally set for June 19th has been continued to July 17,
1995. I am scheduled to be on vacation for the period from July 1 to July 19th and
would appreciate it if the hearing could be rescheduled to a date after my return.
Thank you for your consideration of this request.
Sincerely,
JACOBSEN & MILKES
B9:2:~
ACJ\me
corr\06210Ier,pen
cc: Paul Orr, Esq.
Shana Penner
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