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LEEANN RABANAL, I IN TilE COURT OF COMMON PLEAS OF
Plaintiff I
I CUMBERLAND COUNTY, PENNSYLVANIA
v. I
I NO. 95-11.'I7CIVIL TERM
DINO RABANAL, I
Defendant I PROTECTION FROM ABUSE AND CUSTODY
TBMPORARY PROTECTION ORDBR
AND NOW, this
]IJ day of July, 1995, upon presentation and
consideration of the within Petition, and upon finding that the
plaintiff, LEEANN RABANAL, now residing at an undisclosed location,
is in immediate and present danger of abuse from the defendant,
DINO RABANAL, 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 or
children except by further order of Court,
The defendant, DINO RABANAL, (SSNI 151-52-4884) (D.O.B. I
5/5/56) now residing at 50 Seavers Road, Newville, Cumberland
county, P~nnsylvania, is hereby enjoined from physically abusing
the plaintiff, LEEANN RABANAL, or placing her in fear of abuse,
The defendant is ordered to stay away from any residence where
the plaintiff may be residing, except for the limited purpose of
transferring custody of the parties' children. The defendant shall
remain in his vehicle at all times during the transfer of custody.
The defendant is ordered to refrain from having any direot or
indirect contact with the plaintiff including, but not limited to,
. ViI;.
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telephone and written communications, excspt for ths limited
purpose of facilitating custody arrangsments.
The defendant is enjoined from harassing and stalking the
plaintiff and from harassing the plaintiff's relatives.
The defendant is enjoined from entering the plaintiff's place
of employment and the day care facilities of the minor children.
The defendant is enjoined from removing, damaging, destroying
or selling any property owned jointly by the parties or owned
solely by the plaintiff.
A violation ot this Order may subject the detendant tOI il
arrest under 23 Pa. C.S. 5U13; H) a private criminal complaint
under 23 Pa. C.S. 5&113.1; iii) a charge of indirect criminal
contempt under 23 Pa. C.s. 5&114, punishable by imprisonment up to
six months and a tine ot $100.00-$1,000.00; and iv) civil contempt
under 23 Pa. C.s. 5&114.1. Resumption ot co-residence on the part
ot the plaintitt and detendant shall not nullity the provisions ot
the court order.
This Order shall remain in effect 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.
Temporary custody of Michael Rabanal and Ethan Rabanal, is
hereby awarded to the plaintiff, LEEANN RABANAL.
This Order shall remain in effect until modified or terminated
by the court after notice or hearing. A hearing shall be held on
,I,
"
,,,m., in
this matter on the
Courtroom No. 11
Pennsylvania.
The plaintiff may proceed without pre-payment of fees pending
day of July, 1996, at
cumberland county Courthouse, Carlisle,
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
feee, but service may be accomplished under any applicable rule of
civil Procedure.
This Order shall be docketed in the office of the Prothonotary
and forwarded to the Sheriff for service. The Prothonotary shall
not send a copy of this Order to the defendant by mail.
The Pennsylvania State Police and the camp lIi11 Borough Police
Departments shall 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 violatlon 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),
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LEEANN RABANAL,
P laintif f
I IN TilE COUltT 01' COMMON I'I,IIA/I 01'
I
I CUMBERLAND COlJN'I'V, I'lmNaVINANIA
I
1 NO. 95-1I.'I'/CIVlI, 'l'EltM
I
I PROTECTION FHOM AllURE AND ClJR'I'OJ>V
v.
DINO RABANAL,
Defendant
HOT I 0 II
You have been sued in court, If you wish to defend against
the claims set forth in the following pages, you must take aotion
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 ohjeotions to
the claims set forth against you. You are warned that if you tail
to do so the Court may proceed without you, and a judgment may be
entered against you by the Court without further notiae for any
money claimed in the Petition or for any other claim or relief
requested by the plaintiff, You may lose money or pl-operty or
other rights important to you.
rill MID 001'1'1
If the case goes to hearing and the judge grants a Proteotion
order, a surcharge of $25,00 will be assessed against you, You may
also be required to pay attorney fees to Legal servioes, Ino. for
their representation of the plaintiff,
You .hould take thi. paper to your lawyer at onoe. If you do
not have a lawyer or oannot afford one, QO to or telephone the
offioe .et forth below to find out where you oan Qet leQal help.
COURT ADMINISTRATOIt, 4th fLOOR
CUMBERLAND COUN1'V COUHTIIOUSE
CARLISLE, PENNBVINANIA 1701)
TELEPIIONE NUMBER I (717) 240-f>2110
AMBRICANS WITH DISABILITIIS ACT or 1..0
The Court of Common Pleas of Cumberland county is required by
law to comply with the Amerioans with Disabilities Act of 1990.
For information about accessible facilities and reasonabls
accommodations available to disabled individuals having business
before ths court, please contact our office, All arrangements must
be made at least 72 hours prior to any hearing or business before
the court.
LEEANN RABANAL,
plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 95- J(J'IJ 7 CIVIL TERM
I PROTECTION FROM ABUSE AND CUSTODY
v.
DINO RABANAL,
Defendant
PETITION FOR PROTECTION ORDER
AND CUSTODY
RBLIBF UNDBR THE PROTECTION FROM ABUSB
ACT, 23 P.S. S 6101 et .eq.
A. ABUSE
1. The plaintiff, LEEANN RABANAL, is an adult individual
whose permanent residence is located at 50 Seavers Road, Newville,
Cumbsrland County, Pennsylvania, 17241.
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, DINO RABANAL, (SSNI 151-52-4884) (D.O.B.I
5/5/56), is an adult individual residing at 50 Seavers Road,
Newville, Cumberland County, Pennsylvania, 17241.
4. The defendant is the husband of the plaintiff.
5. Since approximately 1986, the defendant has attempted to
cause and has intentionally caused bodily injury, to the plaintiff,
has placed the plaintiff in reasonable fear of imminent serious
bodily injury, and has knowingly engaged in a course of conduot or
repeatedly committed acts toward ths plaintiff under circumstances
which has placed the plaintiff in reasonable fear of bodily injury.
This has included, but is not limited to, the following specific
instances of abusel
a) On or about July 4, 1995, tho dofondant became
enraged and threatenod the plaintiff by saying that, "he
would 'kill three birds with one stone,'" causing the
plaintiff to fleo her home foaring for hor safoty.
b) On or about Hay 14, 1995, whilo tho plaintiff was
lying on the bed, tho dofondant punched tho plaintiff
about the head and arms causing bruising on the
plaintiff's armsl grabbed tho hor by tho throat with his
handl choked her until sho fell to tho floorl threw the
plaintiff several foot across the rooml and kicked her
about the hip and thigh causing a bruiso and cuts. When
the defendant drove away in his car, the plaintiff drove
to the state police and tolophoned the Domestic Violence
Hotline where she was advised to go to the hospital. At
the hospital, photographs were takon of the plaintiff's
injuries, The Pennsylvania state Police filed charges
against the defendant for simplo assault,
c) On or about t'obruary 1995, tho do fondant grabbed the
plaintiff by the throat with his hand and pushed her
a9a i n.t a wa 11 caus i ng brui eos on her arm, and choked the
plaintiff until sho foil to tho floor. While the
plaintiff was still on the floor, the defendant kicked
her about the hip, causing bruises. The plaintiff fled
to the upstairs for tho rost of the evening.
d) Since approximately 1986, on several different
occasions, the defendant punched the plaintiff about the
head, arms and back, choked her leaving marks on her
throat, kicked the plaintiff about her thighs and hips,
and threatened to kill the plaintiff if she leaves with
the children,
6. On or about July 4, 1995, the plaintiff and the two minor
children left their residence at 50 Seavers Road, Newville,
Cumberland County, Pennsylvania, in order to avoid further abuse.
7. The plaintiff believes and therefore avers that she is in
immediate and present danger of abuse from the defendant and that
she is in need of protection from such abuse.
8. The 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, except for the limited purpose of facilitating
custody arrangements.
9, The plaintiff desires that the defendant be enjoined from
harassing and stalking the plaintiff, and from hBrassing the
plaintiff's relatives.
10. The plaintiff desires that the defendant be restrained
from entering her place of employment and day care facilities of
the minor children.
11. The plaintiff desires that the defendant be enjoined from
removing, damaging, destroying or selling any property owned
jointly by the parties or owned solely by the plaintiff,
B. IXCLU8IVI P0881SSION
12. The home from which the plaintiff is asking the Court to
order the defendant to stay away from is not the marital home, is
not owned or rented in the defendant's name, and the defendant has
never resided there.
C. ATTORNIY FIBS
13. The plaintiff asks that the defendant be ordered to pay
reasonable attorney fees to Legal Services, Ino.
D. TIKPORARY CUSTODY
14. The plaintiff seeks temporary custody of the following
children:
IiUI
pr...nt R..id.nc.
undisclosed location
6 years
DOB 12/5/88
Aa
Michael Rabanal
Ethan Rabanal
undisclosed location
3 years
008 12/20/91
The children were not born out of wedlock.
The children are pressntly in the custody of the plaintiff,
LEEANN RABANAL, who is residing at an undisclosed location.
During the past five years, the children have resided with the
following persons and at the following addressesl
IiUI Addu.... Dat..
pla inti ff undisclosed location 7/4/95 to
l.t to
plaintiff 50 Seavers Road 1989 to
and defendant Newvi 11e, Pennsylvania 7/4/95
The plaintiff, the mother of the children, is LEEANN RABANAL,
currently residing at an undisclosed location.
She is married.
The plaintiff currently resides with the following persons I
IiIIu Relationehip
Michael Rabanal son
Ethan Rabanal son
The defendant, the father of the children, is DINO RABANAL,
currently residing at 50 Seavers Road, Newville, Cumberland County,
Pennsylvania.
He is married.
The defendant currently resides alone.
15. The plaintiff has not previously participated in any
litigation concerning custody of the above mentioned children in
this or any other Court.
16. The plaintiff has no knowledge of any custody proceedings
concerning these children pending before a court in this or any
other jurisdiction.
17. 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.
18. The best interests ann 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 I
a. The plaintiff is a responsible parent who can best
take care of the minor children.
b. The dsfendant has shown by his abuse of the
plaintiff that he is not an appropriate role model for
the minor children.
WHEREFORE, pursuant to the provisions of the IIprotection from
Abuse Act" of October 7/ 1976/ 23 P.S. S 6101 i!.t tuN., as amended,
the plaintiff prays this Honorable Court to grant the following
reliefl
A. Grant a Temporary Order pursuant to the "Protection
from Abuse Actl"
1. Ordering the defendant to refrain from abusing
the plaintiff or placing her in fear of abuse.
2. ordering the defendant to refrain from having
any direct or indirect contact with the plaintiff
including, but not limited tOt telephone and
written communications, except to facilitate
custody arrangements.
3. ordering the defendant to refrain from
harassing and stalking the plaintiff and from
harassing the plaintiff's relatives.
4. Prohibiting the defendant from entering the
plaintiff's place of employment or the day cars
facilities of the minor children.
!I. Prohibiting the defendant from removing,
damaqing, destroying or selling property jointly
owned by the parties or owned solely by the
plaintiff.
6. ordering the defendant to stay away from any
residence the plaintiff may in the future establish
for herself.
7. Granting temporary custody of the minor
children to the plaintiff.
B. Schedule a hearing in accordance with the provisions of
the IIprotection from Abuse Act/" and, after such hearing, enter an
order to be in effect for a pericd of one year:
1. Ordering the defendant to refrain from abusing
the plaintiff or placing her in fear of abuse.
2. Ordering the defendant to refrain from having
any direct or indirect contact with the plaintiff
including, but not limited tOt telephone and
written ccmmunications, except to facilitate
custody arrangements.
3. ordering the defendant to refrain from
harassing and stalking the plaintiff and from
harassing the plaintiff/s relatives.
4. Prohibiting the defendant from entering the
plaintiff's place of employment or the day care
facilities of the minor children.
5. Prohibiting the defendant from removing,
damaging, destroying or selling property jointly
owned by the parties or owned solely by the
plaintiff.
-
6. ordering the defendant to stay away from any
residence the plaintiff may in the future establish
for herself.
7. Granting custody of the minor children to the
plaintiff.
8. ordering the defendant to pay reasonable
attorney fees to Legal Services, Inc.
The plaintiff further asks that this Petition be filed and
served without payment of fees and costs by the plaintiff, pending
a further order at the hearing, and that certified copies of this
Petition and Order be delivered to the Pennsylvania state Police
and the Camp Hill Borough Police Departments who have jurisdiction
to enforce this Order.
The plaintiff prays for such other relief as may be just and
proper.
Respectfully submitted,
v;/~ ( g/~lr
Philip iriganti or
Joan carey
Attorney for Plaintiff
LEGAL SERVIOES, INO.
a Irvine Row
carlisle, PA 17013
(717) 243-9400
The above-named plaintiff, LEEANN RABANAL, 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. 54904 relating to unsworn
falsification to authcrities.
/
Datel
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Plaintiff
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LEEANN RABANAr"
Plainti ff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
..H'n
NO, 95-~ CIVIl. TERM
v.
DINO RABANAI.,
nefendllnt
PROTECTION FROM ABUSE AND CUSTODY
QnpRILJo'OIL (;QN'I' UiIJ!\.N(;!l
AND NOW, this ".I dllY of July, 1995, upon consideration of
the attached Motion for Continullnce, t.he hearing in t.he above-
captioned case is cont.inued generally t.o afford t.he parties time to
execute 1\ Consent. Agreement.
The Temporllry Prot.ection Order shall remain in effect for a
period of one yellr or unt.il modified or terminated by the court
after notice or hearing,
Certified copies of t.his Order for Continuance will be
provided tc the Pennsylvanill State and Camp Hill Borough Police
Departments by the plaintiff's at.torney,
I
By the Court,
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Jcan Carey - CR,,~, t~p4JIil ~~" 7/IJI'ls-
LEGAl. SERVICES / INe. I
Attorney for Plaintiff
Michllel Scherer . 'lII'tl<< "I/lJl.,l .,/tl/~l'
O'BRIEN, BARIC & SCHERER
Attorney for Defendllnl
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I,EEANN RABANAl"
Plaint! ff
I N TifF. COURT OF COMMON PI.EAS OF
CUMHERLAND COUNTY, PENNSYLVANIA
NO. 95-3637 CIVIL TERM
PROTECTION FROM ABUSE AND CUSTODY
v.
D I NO RABANAI"
Defendant
HPT BUl..yoR CON'!' 1!iI/MillB
The plaintiff moves the Court for an Order continuing
ganerally the hearing on t.he groundfl that:
1, A Temporary Protection Order was issued by this Court on
July 7, 1995, scheduling a hearing for July 13, 1995, at. 10:30 a.m,
2. The Cumherlanrl County Sheriff's Department served the
defendant wit.h a certified copy of the Temporary Protection Order
and Petition for Protection Order on July 7, 1995, at approximatelY
6110 p,m. at. 50 Seavers Road, Newville, Pennsylvania.
3. The defendant has retained Michael Scherer of O'Brien,
Baric & Scherer to represent him in the matter.
4, The parties, hy and through their counsel, agree to the
entry of an Order generally continuing the hearing scheduled for
,July 13, 1995, in order to give them time to execute a consent
agreement,
5, The pia i nl I ff requestll thilt the Temporary Protection
Order remain in effect for il period of one year or until modified
or lerminnleel hy the courl' after notice or hearing,
6, Certified ('opieR Df t.IHl oreler for continuance will be
dellvored to thfl PennsylvAni,l Stato and the Camp Ifill Borcugh
Pol ke Departmolil't; hy the attornuy for thl! plaint! ff,
WJlIlIIF:rORIl, the l'l~jnlifr requIlRls that 11111 COllrt grant lhla
Mol Ion IInd continue thlB ,"nUer 09I1fJl'i\1Iy, Ilncl that the Temporarv
Proterl1 Ion order I'fllnllil1 in effect: lint II further Orrlar of Courl.
ReS\lAl1tfully Huhmittllrl,
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f.IWAr. BRRVTCRB, THe.
B Jrv I no Row
Carllslo, PA 17013
(717) 243-9400
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LEEANN RABANAL, I IN THE COURT OF COMMON PLEAS OF
Plaintiff I
I CUMBERLAND COUNTY, PENNSYLVANIA
v. I NO. 95-~~ CIVIL TERM
:
DINO RABANAL/ :
Defendant : PROTECTION FROM ABUSE
AND NOW,
PROTBO~
this ~ day of , 1995/ upon consideration
of the Consent Agreement of the parties, the following Order is
entered I
1. The defendant, DINO RABANAL, is enjoined from physically
abusing the plaintiff, LEEANN RABANAL, or from placing her in fear
of abuse.
2. The defendant is enjoined from having any direct or
indirect contact with the plaintiff including, but not limited tOt
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 prohibi ted from entering the plaintiff's
place of employment.
5. The parties are enjoined from removing, damaging,
destroying or selling any property cwned jointly by the parties or
owned by the other party absent the parties' consent.
6. The defendant is ordered to stay away from the
plaintiff's residence or any residence the plaintiff may in the
future establish for herself, except for tho limited purpcse of
transferring custody, during which times the defendant shall remain
in his vehicle.
7. Neither party shall relccate cut of the central
Pennsylvania area without the written consent of the other party or
a modification of the custody Order.
8. The following is ordered regarding custody of the
parties' children, Michael Rabanal and Ethan Rabanal:
a. The parties shall have shared legal custody.
b. The mother shall have primary physical custody.
c. The father shall have partial custody of the
children every other weekend from Friday at 4130 p.m.
until Monday at 9:00 a.m./ and cne evening during the
week following the weekend the children are nct in his
custody at a time mutually agreed upon by the parties.
The father shall pick up the children at and return them
to their sitter's residence unless agreed upon by the
parties.
d. Each party shall have a one week vacation with the
children, which shall include two weekends. The parties
shall give each other 30 days notice as to when they wish
to take their vacation.
e. Each party shall notify the other immediately of
medical emergencies which arise while the children are in
that parent's care.
liiI.
f. Neither party shall do anything which may estrange
the children from the cther parent, or injure 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.
g. Either party may petition to change the custody
order, but the parties agree that the custody schedule
remains in effect pending further order.
9. Court costs and fees are waived.
10. The Protection Order shall remain in effect for a period
of one (1) year and can be extended beyond its original expiration
date if the Court finds that the defendant has ccmmitted an act of
abuse or has engaged in a pattern or practice that indicates risk
of harm to the plaintiff on a continued basis. This Order shall be
enforceable in the same manner as the Court's prior Tempcrary
Protection Order entered in this caee.
11. The Protection Order may subject the defendant tOI i)
arrest under 23 Pa. C.S. S6113/ 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. S6114.1. Resumption of co-residence on the part
of the plaintiff and defendant shall not nullify the provisions of
the court order.
12. The Pennsylvania state Police and the Camp nill Police
Departments shall be provided with certified copies of this Order
by the plaintiff's attorney and may enforce this order by arrest
fcr indirect criminal oontempt without warrant upon probable oause
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 distriot justice.
(23 Pa. C.S. S 6113).
By the courh / ) I
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~GI 1M nO \1 1\ Mil
v.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 95-3637 CIVIL TERM
LEEANN RABANAL,
plaintiff
DINO RABANAL/
Defendant
PROTECTION FROM ABUSE
CONSENT AGREEMENT
o,+.'..r
Sept!elllliltn:',
f'1.
This Agreement is entered on this I, day of
199fi, by the plaintiff, LEEANN RABANAL, and the defendant, DINO
RABANAL. The plaintiff is represented by Joan carey of LEGAL
SERVICES, INC.; the defendant is represented by Michael Scherer of
O'BRIEN/ BARIC
& SCHERER, 17 W. South Streett Carlisle,
Penrysylvania. The parties agree that the following may be entered
as an Order of Court.
1. The defendant, DINO RABANAL, agrees to refrain from
abusing the plaintiff / LEEANN RABANAL, ot' placing her in fear of
abuse.
2. The defendant agrees not to have any direct or indirect
contact with the plaintiff including, but nct limited to, telephone
and written communications, except for the limited purpose of
facilitating custody arrangements.
3. The defendant agrees not tc harass and stalk the
plaintiff and harass the plaintiff's relatives.
4. The defendant agrees not to enter the plaintiff's place
of employment.
5. The parties agrees to refrain from removing, damaging,
destroying or selling any property owned jointly by the parties or
owned by the other party absent the parties' consent.
6. The defendant agrees to stay away from the plaintiff's
residence or any residence the plaintiff may in the futurs
establish for herself, except for the limited purpose of
transferring custody, during which times the father will remain in
his vehicle.
7. The parties agree that neither party will relocate out of
central Pennsylvania without the written ccnsent cf the other party
or a modification of the custody order.
8. The defendant, although entering into this Agreement,
does not admit the allegaticns made in the Petition.
9. The defendant and the plaintiff agree to the following
regarding custody of their children, Michael Rabansl and Ethan
Rabanal:
a. The parties will have shared legal custody.
b. The plaintiff shall have primary physical custody of
the children.
c. The defendant shall have partial custody of the
children every other weekend from Friday at 4130 p.m.
until Monday at 9100 a,m./ and cns evening during the
week following the weekend the children are not in his
custody at a time mutually agreed upon by the parties.
The father shall pick up the children at and return them
to their sitter's residence unless agreed upon by the
parties.
d. Each party shall have one week vacation with the
children, which shall include two weekends. The parties
shall give each other 30 days notice as to when they wish
to take their vacation.
e. Each party shall notify the other immediately of
medical emergencies which arise while the children are in
that parent's care.
f. Neither party shall do anything which may estrange
the children from the other parent, or injure the opinion
of the children as to the other parent or which may
hamper the free and natural develcpment of the children's
love or respect for the other parent.
g. Either party may petition to change the custody
order, but the parties agree that the custody schedule
remains in effect pending further order.
10. The defendant understands that the Protection Order
entered in this matter will be in effect for a period of one (1)
year and can be extended beyond its criginal expiration date if the
Court finds that the defendant has committed an act of abuse or has
engaged in a pattern or practice that indicates risk of harm to the
plaintiff on a continued basis. The defendant understands that
this Order will be enforceable in the same manner as the Court's
prior Temporary Protection Order entered in this case.
11. Violation of the Prctecticn Order may subjeot the
defendant tOI i) arrest under 23 Pa. C.S. 56113/ ii) a private
criminal complaint under 23 Pa. C.S. 56113.1/ Hi) 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. S6114.1.
WHEREFORE, the puties roquest that a Protection Order be
terms.
'} /
:1.t~ It., U,;/",
/Joan Carey
Philip Briganti
Attorneys for Plaintitf
LIOAL SIRVIOIS, INO.
a Irvine Row
Carlisle, PA 17013
(717) 243-9400
.s-,) ~t~,
DINO RABANA / De endant
~~
Michael Sclie're
Attorney for Defendant
O'BRIEN, BARIC & SCHERER
17 W. South Street
Carlisle, PA 17013