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FEIIC I A ANN IIAnR,
Plll!n! 1 If
IN fill (OIIH' or lOMMON 1'1 rAS or
ClIMIIFHI AND [OUNlY, I'FNNSYLVANIA
CIVIl ACTION. LAH
V,
JAY BAKER,
Defendant
NO, (J~,d6H CIVil TERM
IN RE: PROTECTION FROM ABUSE
ORDER OF COURT
AND NOW, this 13th day of JUly, 1995, this matter
having been called on a petition by plaintiff seeking a
protection from abuse order by defendant, and without admissions
by defendant, the parties ogree to enter Into the following
consent order:
1, Defendant sholl not abuse or threaten to abuse
2. Defendant is prohibited from entering into any
separate residence mointoined by plaintiff,
3, This order shall remain in effect for 0 period of
plaintiff .
one year,
4. Starting Monday, July 17, 1995, and on each Monday
thereafter, until super~eded by an order entered follOWing a
support conference before a Domestic Relations Officer,
defendant shall temporarily pay plaintiff $100,00 per week for
the support of the parties' two children,
By the Court.
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Edgai:B'- . oy ley', J,
Matthew .I, Eshelman, ESQul re ., IQ.r.
For Plaint! ff ._ ('.,~,~....._ {l''''~J'..t 1/1:'; P
John p, Kachur, Esquire
For Defendant
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FELICIA ANN BAKER,
Plaintiff
I IN THE COURT OF COMMON PLEAS OF
I CUMBERLAND COUNTY, PENNSYLVANIA
I I')' rl . A'j
I No. 1 J) {f h \', l" t)1t 1"-
I
I CIVIL ACTION - LAW
I PROTECTION FROM ABUSE
vs.
JAY BAKER,
Defendant
TEMPORARY ORDER
AND NOW, this f,,-j day of : /~( (~
upon review of the Petition of Plaintiff, tK~
following Temporary Orderl
1. The defendant shall refrain from abusing, harassing,
threatening, or stalking the Plaintiff or the minor children or
placing any of them in fear of abuse in any place where they may
be found.
1995,
Court enters the
2. The defendant is enjoined and prohibited from living at,
entering, attempting to enter, or visiting the residence of
Plaintiff located at a confidential address within this County,
which address remains confidential to protect Plaintiff from the
danger of future abuse by the defendant, and any subsequent
residence in which Plaintiff resides during the pendency of this
Order, and Plaintiff is granted exclusive possession of the
premises.
3. The defendant is prohibited from having any contact with
the Plaintiff, including, but not limited to, entering the place
of employment, business, or school of the Plaintiff or the minor
children, and from harassing the Plaintiff.
4. The Plaintiff is awarded temporary custody of the minor
children Jayson K. Baker and Courtney A. Baker.
5. The defendant is ordered to provide the following
additional relief I -~-
6. This Order shall be enforced by any law enforcement
agency in a County where a violation of this Order occurs.
7. Law enforcement officers, the staff of the County
Registry of Protection Orders, and Court personnel shall not
disclose the address of the domestic violence program or any
confidential address of the plaintif f to the defendant, hie
counsel, or any third party.
8. A ccpy of this Order shall be served on the Carlisle,
Mechanicsburg, and Hampden Township police departments. This
Order shall, likewise, be served on the state Police. A copy cf
this Order shall be forthw1th filed in the County Registry of
Protection Orders. Copies shall also be provided to the Sheriff,
the Prothonotary, the plaintiff's counsel, and the plaintiff.
9. The Sheriff or_---
(Specify other adult individual) is directed to serve and file
the aforementioned copies of this Order without prepayment of
costs. Said copies shall be certified.
10. This Order shall remain in full force and effect until
modified or terminated by this Court.
11. The defendant's Social Security number is 183-48-3116.
The date of birth of the defendant is July 10, 1995.
12. A hearing shal:.be held on the FlU. day of _11. Co
1995 at '(./<:; ~.M;/P.M. in courtroom No. JJ of the
Cumberland County Court House, located at One Courthouse Square,
Carlisle, Pennsylvania 17013.
13. THIS IS AN ORDER OF COURT. ANY VIOLATION OF THIS ORDER
SHALL CONSTITUTE CONTEMPT OF COURT AND MAY BE PUNISHABLE BY A
FINE UP TO $1,000.00 AND A JAIL SENTENCE OF UP TO SIX MONTHS.
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I IN THE COURT OF COMMON PLEAS OF
I CUMBERLAND COUNTY, PENNSYLVANIA
I
I No.
I
I CIVIL ACTION - LAW
I PROTECTION FROM ABUSE
FELICIA ANN BAKER,
Plaintiff
JAY BAKER,
Defendant
PBTITION FOR PROTBCTION FROM ABUSB
TO THE HONORABLE JUDGE OF SAID COURT:
1. My name is Felicia Ann Baker. I am the Plaintiff in this
case. I am an adult individual.
2. I live in this County at an undisclosed address for my
protection.
3. I am filing this Petition for temporary and final
protection Orders pursuant to the Protection From Abuse Act, 23
Pa.C.S.A. Section 6101 et seq. I am also seeking relief as
guardian for the children whose names are Courtney A. Baker and
Jayson K. Baker.
4. The abused persons are living in this County at an
undisolosed address for their protection.
5. The person I am filing this Petition against is Jay
Baker, the defendant, who resides at 152 Faith Circle, Carlisle,
Cumberland County, Pennsylvania 17013.
6. The defendant's Social Security number is 183-48-3116.
The defendant's date of birth is July 10, 1959.
7. The defendant is related to the abused person( s) as
husband and father.
8. The defendant works at Surface Preparation Technology,
Inc., located at 81 Texaco Road, Mechanicsburg, Pennsylvania
17055.
9. I cannot reveal the name(s) of the owner(s) or renter(s)
of the residence from which I am asking the Court to exolude the
defendant, for the name(s) will disclose the whereabouts of the
abused psrson (s) whioh must be kept oonfidential for their
proteotion.
10. The facts of the most recsnt inoident of abuse are as
follows I
Datel July 5, 1995
Timel 1100 a.m. and 4100 a.m.
Locationl 152 Faith Circle, Carlisle, pennysylvania
and 19 Fieldstone Drive, Mechanicsburg, Pennsylvania
statement I I was sleeping when the defendant woke me
up. lie stated that he had a gun hidden behind his back. I
called a girlfriend, who immediately came over. The
defendant began to push first my friend, then me. I called
911. While I was on the phone, the defendant picked me up
and threw me down very hard. The police arrested the
defendant. I went to my friend's house. The defendant made
bail with the condition that he stay away from me. lie
guessed where I was, came there, and tried to break in. The
police arrested him a second time. I did seek an evaluation
for medical treatment.
11. The defendant has physically abused me and/or the minor
children in the past. The following are some examples of past
abusive conduct I
A. One day, when I returned home from work, the
defendant was angry with another person and took his anger
out on me by whacking me and throwing things at me. Date
unknown.
B. Another time, the defendant was angry for no
apparent reason. lie grabbed me and threw me down. I
suffered bruises. Date unknown.
C. The defendant has pushed-shoved-punched and thrown
me many times in the past.
12. The abused person(s) are in immediate danger of further
abuse and a Court Order is necessary to protect the abused.
13. I believe that service cannot be safely effected by an
adult individual other than a law enforcement officer.
14. I ask for attorney fees and oosts pursuant to the
Proteotion From Abuse Act.
15. The abused and/or I have suffered out-of-pocket losses as
a result of the defendant's abuse.
16. The defendant has used or threatened to use the following
weapons in his abuse against the abused person(s) I motor vehicle,
gun, small appliances.
WBBRBFORB, Plaintiff requests that this Honorable Court
award the following rsliefl
A. Grant a Temporary Order pursuant to the Protection from
Abuse Actl
Ordering the defendant to stop abusing, harassing,
threatening, and/or stalking the abused and the Plaintiff, and to
stop placing the abused and the Plaintiff in fear of abuse in any
place where they may be found;
Evicting the defendant from a confidential address at
which the abused is now living and from any subsequent residence
in which the abused lives during the pendency of this Order, and
granting exclusive possession of the premises to the abused;
Ordering the defendant to provide and pay for alternative
suitable housing for the abused, approved by the Plaintiff, and
granting exclusive possession of the housing to the abused;
Prohibiting the defendant from having any contact with
the abused, including, but not limited to, restraining the
defendant from entering the place of employment, business, or
school or recreation of the abused and from harassing the abused
or the abuseds' relatives;
Granting temporary custody of the minor children to the
Plaintiff;
Directing the Sheriff's Department of Cumberland County
(or other law enforcemsnt agency) to serve a copy of the Petition
and Temporary Ordsr upon the defendant without prepayment of
costs;
Directing that the Petition and Order in this matter may
be served upon the defendant without the disclosure of the
address of the abused, and also directing the police and all
Court personnel not to reveal any residential address of the
abused to the defendant, his counsel, or any third party; and
B. Schedule a hearing and, at such hearing, enter a one-year
Order which includes the above in addition to the following I
Granting temporary support for the abused in the maximum
amount allowed under lawl
Ordering the defendant to reimburse Plaintiff's and the
abused's out-of-pocket losses suffered as a result of the abuse;
-,.
FELICIA ANN BAKER,
Plaintiff
vs.
JAY BAKER,
Defendant
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facts set forth in
I IN TilE COUR'l' OF COMMON PLEAS OF
I CUMBERLAND COUN'l'Y, PENNSYLVANIA
I
I No.
I
I CIVIL ACTION - LAW
I PROTECTION FROM ABUSE
VERIPICATION
A -'") /.
tlt1.1 ~tJ:.1..'cr
, state that I am the
in the above-captioned case and that the
the above "I)/')'M .(" 1-11{ are true and
oorrect to the best of my knowledge, information, and belief. I
realize that false statements herein are subjeot to the penalties
for unsworn falsifioation to authorities under 18 Pa. C.S. S
4940.
Date,)"- )'"crS
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