HomeMy WebLinkAbout95-06062
CERTIFICA n; m'S.:RVln:
I, Lisa Marie Coyne, Esqoirc, herchy certify that truc cupy uf the lilrcguing I'reheoring
Memorandum was this date served upon the bclu\\'.rcfercnccd individuuls by pcrsunul servicc:
Gerold S. Robinson, Esquire
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ol11pllill.I'A 170\ 1..4227
(717) 737.()4c.4
1'0. S. CI. No. 53788
ROBERT C. RAMSEY, I IN THE COURT OF CCX>\MON PLEAS OF
petitioner I CUMBERLAND COON'l'Y, PENNSYLVANIA
I
vs. I NO. 95-6062 CIVIL TERM
I CIVIL ACTION - LAW
MARILYN S. RAMSEY, I
Respondent I IN CUSTODY
CIU1IlR OF (DIRT
AND lOft this .1.4 ,e)day of LhtNU
consideration of the at~custody Conc at on Report,
and directed as followSl
, 199B, upon
t is ordered
Bearing is scheduled in Courtroan No.5, of the
ounty Court Biu.se. A on the ~ day of
, 199B, at ~ o'clock, A-.m., at which time
be taken in this case. At the Beartng, the Father, Robert
C. Ramsey, shall be deemed to be the moving party and shall proceed
initially with testimony. counsel for the parties shall file with the
Court and opposing counsel a Memorandum setting forth each party's position
on custody, a list of witnesses who will be called to testify at the
Bearing, and a summary of the anticipated testimony of each witness. These
Memoranda shall be filed at least ten (10) days prior to the Bearing date.
2. Pending the Bearing, the Mother and the Father shall have shared
legal custody of the Children, with the Mother having primary physical
csutody of the parties' daughter, catherine Anne Ramsey, and the Father
having primary physical custody of the parties' son, Matthew Philip Ramsey.
3. In the event the Mother relocates with Catherine to Atlanta,
Georgia pending Bearing, each party shall have partial physical custody of
both Children together on alternating weekends from Friday at 5100 p.m.
through sunday at 7:00 p.m., beginning with the Mother having custody of
the Children over the first weekend she is residing in Atlanta.
4. Each party shall have liberal telephone contact with the child who
is not in that party's custody. Such telephone contact shall not be
hindered or supervised by the other party.
5. Within five (5) days of the custody condliaiton Conference, the
Mother shall provide to the l'ather, through counsel, the address and
telephone nUllber where the parties' daughter, catherine, is currently
residing in Illinois.
BY ':;;j1.,
J.
eel Lisa Marie Coyne, Esquire - Counsel for l'ather
SCott W. Pohlman, Esquire - Counsel for Mother
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ROBERT C. RAMSEY,
Petitioner
IN 'l'HE CXlURT OF CQ'olMOO PLEAS OF
; CUMBERLAND COUNTY, PENNSYLVANIA
;
vs.
NO. 95-6062 CIVIL TERM
MARILYN S. RAMSEY,
Respondent
CIVIL AC'l'ION - LAW
CUSroDY
PRIOO JUDGB: Harold E. Sheely I'.J.
CUS'lalY ClKILIATIOO SlMWU' RBPCRT
IN A<XnmANCB wml ClJIlBBRLAND aun'lt' RULE CI." CIVIL POCo '1<1 (1m
1915.3-8, the undersigned CUstody Conciliator submits the following report:
1. 'It1e pertinent information concerning the Children who are the
subjects of this litigation is as follows:
!!!!!
Matthew Philip Ramsey
catherine Anne Ramsey
MTB CI." BIR'11I
aIlRml'Ly IN CUS'1WY CI."
March 18, 1982
March 24, 1987
Petitioner/Father
Mother/Mother's Aunt
and Uncle
2. A Conciliation Conference was held on January 8, 1998, with the
following individuals in attendance; The Father, Robert C. Ramsey, with
his counsel, Lisa Marie Coyne, Esquire, and the Mother, Marilyn S. Ramsey,
with her counsel, Scott W. Pohlman, Esquire.
3. 'It1is COurt previously entered an order in this matter on December
13, 1995, based upon an agreement reached by the parties at a CUstody
Conciliation Conference. That order provided for the Mother to have
primary physical custody of both Children and the Father to have periods of
partial physical custody. Within a short time after the order was entered,
the parties reconciled and then lived in the same reaidence until November
1997 when the Father filed this Petition for custody and approval to
relocate with the Children to Atlanta, Georgia. An expedited hearing was
scheduled prior to the Fatherrs move but was continued at the Mother's
request to allow her to obtain other legal cOlmse1. The Father moved to
Atlanta, Georgia on or about December la, 1997 and took the parties' son,
Matthew, with him and Matthew is currently enrolled in the paulding County
School District in Atlanta. 'It1e Mother currently resides in CUnberland
County. 'It1e parties daughter, Catherine, is currently staying with the
Mother's aunt and uncle in spring Grove, Illinois where she is currently
enrolled in school.
80th parties are seeking primary physical custody of the Children
and no agreement was reached at the Conference. 'l'herefore, it will be
necesaary to schedule a lIearing in this matter and the Conciliator has
contacted the Court Administrator's Office to request an expedited hearing
due to the fact that the Children are separated and living in different
states with little prospect for either parent to have partial physical
custody with the Child in the other party's custody.
4. The Father's position on custody is as follows: The Father
believes that it would be in both Children's best interest to reside
primarily with him in Georgia. The Father alleged that the Mother has a
psychological disorder, for which she does not regUlarly take medication
and which results in very aggressive and unpredictable behavior around the
Children. The Father indicated that he moved to Atlanta, Georgia due to
his employment and that the extended families of both the Mother and Father
currently reside in Georgia. 1'he Father believes that the parties'
daughter Catherine should be reunited with her brother, Matthew and
nineteen year old sister, Maribeth and that the Father can provide a more
stable home for the Children. According to the Father, the Mother took the
parties' daughter, Catherine to the Mother's aunt and uncle's home in
Illinois without the Father's knowledge. The Father stated that he did not
know the Child had been removed fran Pennsylvania until the time of the
Conference. Also according to the Father, the parties' son is afraid of
the Mother and adamantly refuses to have contact with her.
5. The Mother's position on custody is as follows: The Mother
believes that it would be in both Children's best interest to reside
primarily with her. The Mother indicated that she currently plans to
relocate to either Illinois or Texas (where she has potential employment
opportunities) or possibly to Georgia. The Mother denied the Father's
allegations concerning her failure to take medication or concerning her
behavior toward the Children. The Mother feels the Father has manipulated
the situation in order to deprive her of custody of the parties' son. The
Mother also alleged that the Father has alienated the son from her. The
Mother stated that the Father has no rules or control over the Children in
his household and that the Father discourages the partiesr son from taking
necessary medications. The Mother acknowledged that the parties resided
in the same residence since the last CUstody order was entered in 1995, but
feels that the prior Order should be enforced as written. The Mother
stated that she took the parties' daughter to live with the Mother's aunt
and uncle in Illinois because the Mother plans to relocate soon and the
living conditions in the marital residence (no heat) were not appropriate
for the Child.
6. Pending lIearing, the Conciliator recomnends an Order in the form
as attached. It should be noted that both parties sought to obtain primary
custody of both Children pending the Hearing. The recoomendation, however,
is based upon the fact that both Children were recently enrolled in new
schools after being removed from Pennsylvania and attempts to avoid
additional uprooting until the Court has rendered a final decision. Due to
the extraordinary circumstances involved in this case, the Conciliator
recorrmends that the Hearing in this matter be expedi ted as much as
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RODERT C, RAMSEY,
Plaintiff
: IN TilE COURT OF COMMON I'LEAS OF
: CllMDERLANIl COUNTY, I'ENNSYLV ANIA
vs,
: NO, 95-6062 Civil Tcrm
MARYILYN S, RAMSEY,
Ilcfcndanl.
: CIVIL ACTION -- LAW
: IN ClISTOI)Y
l'ETlTION FOR MOlliFICATION OF CllSTOI)Y OIUlER
AND NOW COMES, the Petitioner, Robert C. Ramscy, by and through his counsel, Liso Marie
Coyne, Esquirc, and IiIcs thc within Petition for Modification of Custody Ordcr for shorcd legol custody
and primary physical custody of his two minor childrcn and in supportthcrcof, avcrs thc following:
I. 11le Pctitioner is Robcrt C. Romsey, who is tcmporarily rcsiding ot Quality Inn, Carlisle,
Pennsylvania.
2. TIlc Respondent is Morilyn Rumsey, residing at 35 Tcabeny Drive, Carlisle,
Cumberland County, Pcnnsylvania.
3, Petitioncr sceks primory physical custody ofthc following childrcn:
~
Prcscnt Addrcss
A>>$..
Matlhew Philip Ramsey
Quality Inn, Carli sic, PA
15 yrs,
(DOB: March 18, 1982)
Catherinc Annc Romscy
35 Teabeny Drive, Carlislc,PA
10 yrs.
(DOB: March 24, 1987)
'lllc childrcn wcrc not bom out of wcdlock.
Currcntly, Matlhcw is in thc custody of thc Pctitioncr and is rcsiding with thc
Pctitioncr/fathcr in tcmporary lodging as abovc statcd and Catherine is in the custody of thc Respondent
and is residing with nespondenllmolher allhe obove.referenced addrcss.. Duringlhe posl five years, Ihe
child has resided with the following persons ond at the lilllowing addresscs:
~
Address:
I'orents:
June 1993 10 Presenl
35 Teaberry Drive, Corlisle,Pennsylvania
Bolh I'arents
and siblings
1989 to June 1993
I'lano, Texas
Bolh I'arents
and siblings
4. The mother of Ihe children is Marilyn Ramsey, who currenlly residcs at 35 TcabelT)'
Drivc, Carlisle, Pennsylvonio. She is manied to Ihe Petitioner.
5. llle father of the children is Robert C. Ramsey, who cU\Tcnlly resides al Quality Inn,
Carlisle, I'ennsylvanio. He is married 10 the Respondent.
6. 11le relationship of I'etitioner to the children is that of naturol father. llle I'elitioner
cU\Tenlly resides with the following pcrsons: Matthew I'hilip Ramsey and Maribeth Ramsey, the parties'
oldesl child, now age 19.
7. 'Ibe relationship of Respondcntto the childrcn is that of natural mother. lbe nespondent
currenlly resides with Catherine Anne namsey, the minor daughter of the parties.
8. In 1995, the parties enlered into a consent order with regard to custody alTUngements for
their children. Subsequent to that order, the purties reconciled and no custody evaluation was rcquired
by agreemenl of the parties and sincc then they have lived together with Iheir children in Cumberlond
County. A copy of the prior Order is attached hereto us Exhibit "A".
10. Petitioner docs not know of n I'ersonnot n party to the proccedings who hns physical
custody of Ihe child or claims to have custody or visitation righls with respect 10 the children.
11. '111e besl intercst nnd penllnncnt welfare of the childrcn will be served by grnnlingtbe
relief requested because the Petitioner, lulher. is beingtranslcrrcd Ihnll his employment in Cumberland
- ../
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DEe 1 1 1~95 If
ROIlERT C. RAMSEr,
Plaintiff
I IN mt o:lUR'l' Cf' CXJoH:'N PLEAS Of'
I ctJIBERLAND CXXN1'Y, PIlNNSYL VANIA
I
I 00. 95-6062 CIVIL TF.RH
I
I CIVIL AC'l'IClQ - LAIf
I OJS'lOOY
va.
HARIL~ S. RAtlS!lr,
Oefenc3ant
~ at In:m
III) -, th1a /3:t1... day of /u"..~,~., , 199.$',
upon cOlllliderat1cn of the attached Cust:~ Caleilillt10n SUIInry Rlport,it
.1. ordered and direct.cl as followlll
1. '1l1e partiea shall lIIlIxnit th_lves end their mnor Chllckon to a
CIlB~ evaluation to t. perfor1llld by Arnold Shilnvold, Phd. Cost of the
eVllluation ehal1 be lhared equally by the parties. Upon the conc:1l1l1ion of
the eval\llltion and in the event the partilll an not at that t1Jna able to
;reach . pltl:lll&l'lerlt 89r-t on custody, either party nay Pltition the COurt
to have thill c:aae again schllilled \lith the CwI~ Coneiliator' for II
ICont"en~.
2. Pending flJt'ther Ordlr of this Court or IIg~t of thl parties,
thl Father shall have prinaty physical ClIlIt~ of Haribeth Rlmey (ag. 17)
end the Mother shall have primary physical custody of Matthew (lIg. 14) end
CatherilKl RllrnMy (llg1 B). The partilll ahal1 have shared 1.1 custody.
, 3. The Father aha11 have partial phYllieal cuatody of Matthw and
catherine Ramley on alternating \llClke~ fran '1l1ureday after school W'Itil
the tollowill9 I'londay morning. During I<edts follOWing IIWkenCl. in which the
Mother had custody of Matthew llI1d catherine, the Father shall have partial
custody of the ChU&'en on Tueaday evening after ""hool until BlJa p.m.
DUring IIKkB fo11O\1ing wekend. in which the Father had eustody of Matth4lll
and Catherine, the FIlther ehall have !f1yaical custody of the Children on
Thur~y eVlninq after .choa1 until 8:30 p.m. '.L'hia alternating weekday
llvenillg ClIlItody schedule eha11 begin on Decellber 5. 1995. The Father's
IIltemating liflekend custOCly schedule shall begin on Decerrber 7, 1995. The
Father shall have tilyaica1 custody of the Children over- the Christ:Jl1lls
holiday in 1995 frau Decent>et' 21 after school I.lI1til Decenber 24 at 12:00
noon and fran Oecembllr 25 at 12:00 noon until 09carber 26 Bt 12:00 noon.
4. '1l1e Mother- shall havB partial physical custody ot Maribeth Ramsey
(egB 17) all mutually a91""" by the partie::!.
5. '1l111l Order ill Intot'ed purllusnt to an &qreement of the parties at a
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CERTIFICA n; OF SERVICE
I, LISA MARIE COYNE, ESQUIRE, herehy eertify lhatl have, on lhe below dote, caused a true
ond correct copies of lhe alloehed Petition for Modification of Custody Order 10 be served upon the
person nomed below by way of certified firsl closs moil, postage prepaid, retum receipt requested:
John J. Connelly, Jr., Esquire
Connelly, Reid & Spade
108-112 Wolnut Street
Horrisburg, I' A 17108
Date: /q NN 17
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ROBERT C. RAMSEY,
I IN THE COURT OF COMMON PLEAS
I CUMBERLAND COUNTY, PENNSYLVANIA
I
I
I No. 95-6062
I
Pet! tioner,
v.
MARILYN S, RAMSEY,
Respondent.
Civil Action - Law in custody
PRE-HEARING MEMORANDUM
Respondent, MARILYN S. RAMSEY, by and through her undersigned
counsel, Gerald S. Robinson, Esquire, submits the following
Memorandum setting forth her position on custody.
1. Respondent concurs with the position statement attributed
to her included in the custody Conciliation summary Report submitted
by Custody Conciliator, Dawn S. Sunday. To support this position
Respondent will present the testimony of the maternal grandparents.
2. To the extent the Court determines that the psychological
disorder alleged by the Petition is relevant to these proceedings,
Respondent contends that only professional psychological evaluations
be considered.
Respectfully submitted,
ROBINSON , GERALDO
~~riil~i~ire
Attorney 1.0. No. 27423
4407 North Front Street
P.O. Box 5320
Harrisburg, Pennsylvania 17110
(717) 232-8525
Attorney for Respondent
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F1I ED-QFRCE
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ROBERT C. RAMSEY,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY. PENNSYLVANIA
vs.
95.f1062 CIVIL
MARILYN S. RAMSEY.
Defendant
PROTECTION mOM ABUSE
ORDER
AND NOW, this
/0'"
day of March, 1'.197, thc dct'cndantls releascd from thc
Cumbcrland County Prison on hcr own rccognizancc. Hcaring in thc abovc caplloncd mallcr set
for Mareh 13. 1997. Is continued to Wcdnesday. May 7.1997, at 1:30 p.m. in Courtroom Numbcr
4. Cumberland County Courthousc, Carlisle. I'A. The temporary order datcd March 5, 19'.17. to
remain in full force and cffcct pcndlng furthcr ordcr of court.
BY THE COURT.
Austin Grogan. Esquire
For thc Plaintiff 'r 1',,~.J NGu<.J,
3Iu.''j't
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John Connclly. Esquirc
For the Dcfendant
CCI'
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SURm, BONDSMAN, REAL TV BAIL BOND
APPLICABLE PORTION OF REVERSE SIDE MUST BE COMPLETED
CERTIFICATION OF BAIL
AND DISCHARGE
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l'A'lli' (1;"'II,li~1
Marilyn s. Ilansey
35 'J'eaberry Drive
Carlisle, PA 17013
00 ROR(no6ulctyl L.I NornmalUal1
o 8011(10181 arnounl &01, II onyl $
lKl CoMlllons 01 R'I,as' (aSide trom appearing III cnur! when requlled I
No contact with plaintiff
contempt
(Violation of Protection
Fron Abuse Order)
to
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COUIlT ACTION
In,"ll()!lCourlroan 4
0J11berland Co. Courtho
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o ProfeSSIonal Bondsman
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Hen. Kevin A. Hess, Jud e
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APPEARANCE OR BAIL BOND
DISCHARGI . ,II ABOVI.NAMED DlflNDANI FROM CuStODY If
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THIS BOND tS VALID FOR THE ENTIRE PROCEEDINGS AND
UNTil FUll AND FINAL DISPOSITION OF THE CASE INCLUDING
FINAL DISPOSITION OF ANY PETITION FOR WRIT OF CERTIORARI
OR APPEAL TIMELY tILED tN THE SUPREME COURT OF THE
UNITED STATES.
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Commonwealth 01 Plnn1V'.lnll tha lum 01 None dolllllll).
SEE REVERSE ~;IU[ JailBAit CONIJITlON~;
CERTIFICATION OF COUN jER INDEMNITY AND PREMIUM (Applicable Only When Surely Is A Corporalton)
PIlllUpJI ,1M "Surety"
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In jail and any other approprlale punishment. Consent of the Plaintiff to the Defendant's
resumption of residence with the Plaintiff shall not Invalidate this Order. The Defendant
shall seek modification (change) of this Order before resuming residence in the Plaintiff's
domicile, wherever it may be.
Temporary custody of Mallhew Ramsey, age 15; and Catherine Ramsey, age 10 Is
hereby awarded to the Plaintiff, ROBERT C. RAMSEY.
The Defendant is ordered to refrain from having any contact with the Plaintiff
(including, but not limited to, restraining the Defendant from entering the place of
employment or business or school of the Plaintiff and from harassing the Plaintiff, Plaintiff's
relatives or minor children.
This Order shall remain in effect until a final order is entered In this case, A hearing
shall be held on this mailer on the /3~ day of '111 tV!. ~"A/ ,1997, at 1fJ-i.M. in
Courtroom No.~, Cumberland County Courthouse, Carlisle, Pennsylvania.
The Plaintiff may proceed in fillnlilnauneris pending a further order after the hearing.
The Cumberland County Sheriff's office shall allemptto make service at the Plaintiff's
request, but service may be accomplished under any applicable rule of Civil Procedure,
The Middlesex, East Pcnnsboro and Silver Spring Township Police Department will
be provided with a copy of this Order by attorneys for Plaintiff. 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 presenC!.! of the police officer. In the event
lhat an arrest Is made under Ihis seclion, the Defendanl shall not be laken to jail bul shall
be laken without unnecessary delay before the court that issued Ihe Order, Whenlhal court
is unavailable, the Defendant shall be arraigned before a distrlcl justice who shall set bail
according to the provisions of Chapler 4000 of Ihe Pennsylvania Rules of Criminal
Procedure (23 Pa.C.S.A, Section 6113).
BY THE COURT.
J,
ROBERT C. RAMSEY,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNlY, PENNSYLVANIA
CIVIL ACTION. LAW
for himself and on behalf
of his minor children
NO. 95.[,062
v.
MARILYN S. RAMSEY,
Defendant
PROTECTION FROM ABUSE
AND CUSTODY
TO THE HONORABLE HAROLD SHEELY, P.J.
PROTECTION FROM ABUSE ORDER
1. The Plaintiff is an adult individual whose address is 35 Teaberry Drive,
Carlisle, Middlesex Township, Cumberland Counly, Pennsylvania 17013, The Plaintiff
brings Ihls action for himself and the parties two minor children; Mallhew, age 15 and
Catherine, age 10.
2. The Defendant Is an adult individual residing at 35 Teaberry Drive, Carlisle,
Middlesex Township, Pennsylvania 17013.
3. The Defendant is the spouse of the PI.llntlfr.
COUNT I
4. On or about Saturday, February 22, 1997, Ihe Defendant assaulted the Plaintiff
by bUllheading him, grabbing his groin and kneeinglhe Plaintiff In the groin area, causing
pain and injury in Ihatthe Plaintiff was required to seek medic.ll allentlon.
5. The Defendant was charged and incarcerated on a count of simple assault and
ordcrcd (Jut of Ihe r1li1lital home.
6, On or about January 6, 1997, the Defendanl again argued and fought with the
Plaintiff striking him and the pmtles minor child Matthew Ramsey.
7. A prior PFA was entered by this Honor,lble Courl which is incorporaled by
reference (prior PFA Petition attached as Exhibit" 1 "l.
8. The Plaintiff believes and Iherefore avers Ihal he and his children will be in
immediate and present danger of abuse frorn Ihe Defendant should he return to the home
with his children without the Defendant's exclusion and that he and his children are In need
of prolectlon from such abuse.
9. The Plaintiff desires that the Defendant be restrained from entering his place
of employment, business or school having any contact with him, harassing the Plaintiff or
Plaintiff's relatives, or minor children or the entering the children's schools.
WHEREFORE, pursuanl to the provisions of the "Protection From Abuse Act" of
October 7, 1976,23 Pa,C.S.A. ~lil0l gl Mm., as amended, the Plaintiff prays this Honorable
Court 10 grant the following relief:
A. Grant a Temporary Order pursuant to the "Protection from Abuse Act:"
1. Requiring the Defendant 10 refrain from ahusing Plaintiff ,1nd his minor
children or placing them in fear of abuse.
2. Requiring Ihe Defendant to refrain from h,lVinll any contact with Ihe
Plaintiff, including, but not limited to, restr,linlng the D('fendanl from entering Ihe place of
employment or husln('ss or school of the Plaintiff's .lIld from harassing Ihe Plainllff, Plaintiff's
relallves or minor childn'n.
3. Granting temporary custody of the Illlnor children to the Plaintiff,
4, Granting possession of 11ll! hOllle located ,It 35 Teaherry Drive, Carlisle,
Middlesex Township, Cumherland County, Penmylviini.lto the Plaintiff 10 the exclusion of
the Defendant pending a final order in Ihis mailer.
5. Ordering the Defendant to stay away from the residence located al 35
Teaherry Drive, Carlisle, Middlesex Township, Cumherland County, Pennsylvania.
6. Ordering the Defendanlto stay away from any residence the Plaintiff
may in the future estahllsh for himself; and
B. Schedule a hearing in accordance with the provisions of the "Protection from
Ahuse Act," and, after such hearing, enter an order to he in effect for a period of one year;
1. Requiring the Defendant to refrain from ahusing Plainllff and his minor
children or placing them in fear of ahuse.
2. Requiring the Defendant to refrain from having any contact with the
Plaintiff, Including, hut not limited to, restraining the Defendant from entering the place of
employment or husiness or school of the Plaintiff's and from harassing the Plaintiff, PI.1lnllff's
relatives or mlnOl children.
3. Granting possession of till' rl'sidei1(l! ,11 :15 Tl'aberry Drive, c.lIllsle,
Mlddlesl'x Township, Cumbl'r1and County, l'ennsylv,lI1i,lto the 1'1,lintlff to the l!xcluslon of
the Defendant.
4. Ordmltllllhe Defendalltto stay aw.ty from the resldellcl! localed at 35
Teaherry Drlvl!, c'lIllsh', Middlesex Towll5hlp, Cumhl'rland County, Pl'llnsylv,lnl,l.
resumption of residence with the Plaintiff shall not invalidate this Order. The Defendanf
shall seek modification (change) of this Order before resuming residence in the Plaintiff's
domicile, wherever it may be.
Temporary custody of ~il\lrm; Maribelh Ramsey, age 17; t.IIlatlJ~
~~t1l.R!m~~, is hereby awarded to Ihe Plaintiff, ROllERT
C. RAMSEY.
The Defendant is ordered to refrain from having any comact with the Plaintiff
(including, but not limited to. restraining the Defendant from entering the place of
employment or business or school of the Plaimiff and from harassing the Plaintiff. Plaintiffs
relatives or minor children.
This Order shall remain in effect until a final order is emered in this case. A hearing
shall be held on this matter on the ;M day of 1'Ln~"'''Y1995. at
I: ,3d P.M. in Courtroom No.L, Cumberland County Courthouse, Carlisle,
Pennsylvania.
l11e Cumberland County Sheriff's office shall allempt to make service at the
Plaintiffs request, but service may be accomplished under any applicable rule of Civil
Procedure.
The Middlesex. East Pennsboro and Silver Spring Township Police Departments will
be provided with a copy of this Order by allorneys for Plaintiff. This Order shall be
enforced by any law enforcement agency where a violation occurs by nrrest for indirect
criminal contempt without wnrram upon probnble cnuse thntthis Order hns been violnted,
whether or not the violation is commilled in the presence of the police officer. In the event
that an arrest is mnde under this seclion, the Defendam shnllnot be taken to jail but shall be
Plaintiff and his childrcn, and by physicalmcnacc has placcd Ihc Plailll;ff and his children in
fear or imminent scrious bodily injury. 11lis has includcd but is not Iimitcd to thc following
spccific instanccs of abuse:
a. On October 16, 1995, Defcndant shovcd and pushcd to thc ground;"tllc
couplc's minor daughtcr, Maribcth Ramsey, uscd obsccne language and spit in the minor's
face.
b. On October 15, 1995, Defendant poured ice watcr on minor, Maribeth
Ramsey, while she was sleeping. The minor left the residence and stayed with a neighbor.
Defcndant then used obscene language with husband degraded him to the panies' s minor
child, Catherine Ramsey. Plaintiff attempted to get away from the Defendant however,
Defendant continued to block Plaintiff's way. Plaintiff went outside in an attempt to again
rcmove himsclf from the violent rages of the Dcfcndant and Defendant then thrcw a pair of
golf shoes at Plaintiff. Plaintiff tllen attemptcd to ignorc Dcfendant by lending to his rose
garden. Defendant thcn produccd a pair of c1ippcrs and bcgan clipping off the roses in a
threatening manner, placing the Dcfcndant in imminent abuse. Plaintiff retrcated to the
family resldcnce when the Defendant followed. Defendant then hit Plaillliff in the right eye,
punched and kickcd at Plaintiff's groin cut off a piece of Plaintiff's hair with a pair of
scissors, dragged Plaintiff around the living room by his hair. Plaintiff then went into the
parties' bedroom and lockcd Ihe door. The Defendant managed to pick the lock of thc
bedroom door and continued to hit and kick Plaintiff. Defendant then obtained watcr from
the parties' bathroom and threw it on Plaintiff and left the parties bedroom. Plaintiff then re-
locked the bcdroom door and barricaded samc. Dcfendant then broke the door from the
hingcs and out of the frame. She then bcgan hitting Plaintiff with the door as he lay on the
bed.
c. On Seprember 9, 1995 pollee were called to the panies' residence. Defendant
had been hitting the Plaintiff. Defendant hit tlte minor, Mattllew Ramsey, causing his mouth
to bleed. The Plaintiff attempted to record lite rantings of tlle Defendant, The Defendant
attempted to oblain tlle recorder. Plaintiff put the recorder in his jeans. Defendant then sat
on the Plaintiff and cut open his jeans in an attempt to obtain the recorder.
d. On February 17, 1995 Defendant asused Ihe minor child, Maribeth Ramsey,
by punching her in tlle face and causing bleeding from the mouth.
e. On January 16, 1995 the police were called to the panies residence.
Defendant again struck the minor, Maribeth Ramsey.
6. On October 16, 1995 the Plaintiff and his one child, Maribeth Ramsey left
their residence at 35 Teaberry, Carlisle, Middlesex Township, Cumberland County,
Pennsylvania in order to avoid funher abuse.
7. The Plaintiff believes and tllerefore avers that he and his children will be in
immediate and present danger of abuse from tlle Defendant should he return to the home with
his children without the Defendant's exclusion and that he and his children are in need of
protection from such abuse.
S. The Plaintiff dcsires thatlhe Defendant be rcstraincd from cntering his place
of employmcnt, busincss or school having any contact with him, harassing the Plaintiff or
Plaintiff's relalives, or minor children or thc entcring the children's schools.
9. Thc Defendant has used or thrcatencd to usc thc following weapons In his
abuse of the Plaintiff (and/or the minor chlldrcn): Scissors.
12. The Plaintiff has no knowlcdge of any custody proceedings concerning these
children pending before a court in this or any other jurisdiction.
13. The Plaintiff does not know of any person not a party to tJlis aClion who has
physical custody of the children or claims to have custody or visilation rights witri respect to
the children.
14. The best interests and permanent welfare of the children will be met if custody
is temporarily granted to the Plaintiff pending a hearing in this mailer because:
a. The Plaintiff is a fit parent who can bestll1ke care of his children.
b. The Defendant has shown by her abuse of the Plaintiff that she is not an
appropriate role model for the children.
c. The Defendant has demonstrated by her abuse of the children that she is an
unfit parent.
C, EXCLUSIVE POSSESSION
IS. The home from which the Plaintiff Is asking the Court to exclude the
Defendant is owned In the names of ROBERT C. RAMSEY and MAIULYN S, RAMSEY.
16. The Plaintiff currelllly has no placc to stay wilh his children except the marital
home.
17. Thc Plaintiff dcsircs posscssion of the homc so as to give the greatest degree
of continuity to lives of thc chiltlrcn ilntl to 1I11ow thcm to continue their education at their
schools and to continue their schoolllntl sodill activitics.
WHEREI'ORE, pursllilnt 1Il the provisions of thc "Protection froll1 Ahuse Act" of
October 7.1976,23 Pa.C.S.A. Section 6101 ~ ~., as amended, the Plaintiff prays this
Honorable Court to grant the following relief:
A. Grant a Temporary Order pursuant to the "Prolection from Abuse Act:"
I. Requiring the Defendant 10 refrain from abusing the Plaintiff and his minor
children or placing them in fear of abuse.
2. Requiring the Defendam to refrain from having any contact with the
Plaintiff, including, but not limited 10, restraining the Defendant from entering the place of
employment or business or school of the Plaintiff and from harassing the Plaintiff. Plaintiff's
relatives or minor children.
3. Granting temporary custody of the minor children to the Plaintiff;
4. Granting possession of the home localed at 35 Teaberry Drive. Carlisle,
Middlesex Township, Cumberland County, Pennsylvania to the Plaintiff to the exclusion of
the Defendant pending a final order in this maller;
5. Ordering the Defendant to stay away from the residence located at 35
Teaberry Drive, Carlisle, Middlesex Township, Cumberland County, Pennsylvania.
6. Ordering the Defendant to stay away from any residence the Plaintiff may
in the future establish for himself; and
B. Schedule a hearing in accordance with the provisions of the "Protection from
Abuse Act." and, after such hearing, enter an order 10 be in effect for a period of one year:
I. Requiring the Defendanl to refrain from abusing the i'laillliff or his minor
children or placing Ihem in fear of abuse.
2. Requiring the Defendant to refrain from having any contact with the
Plaintiff, including, but not limited to, rcstraining the Defendant from cntering the place of
...
employment or business or school of the Plalmiff and from harassing the Plainliff. Plairitiffs
relatives or minor children.
3. Granting possession of the residence at 35 Tcabcrry Drive, Carlislc.
Middlesex Township, Cumbcrland County. Pennsylvania. to the Plaintiff to Ihe cxclusion of
the Defendant.
4. Ordering the Defendant to stay away from the residence located at 35
Teabcrry Drive, Carlisle, Middlesex Township. Cumbcrland Coumy, Pennsylvania.
5. Ordering the Defendant to stay away from any residence the Plaimiff may
in the future establish for himself.
The Plaimiff funher asks that this a copy of this Petition and Order be delivered to
the Middlesex Township, East Pennsboro Township and Silver Spring Township, Police
Departments as the Police Departmems with jurisdiction to enforce this Order.
The Plaintiff prays for such other relief as may be just and proper.
COUNT II
CUSTODY UNDER PENNSYLVANIA CUSTODY LAW
I. The allegations of Count I above are incorporated herein as If fully set forth.
2. The hest Imerests and pennanel1l welfare of thc children will he served by
conf1nning custody in the Plaintiff as set forth in Paragraph 14 of Ihe Petition.
WHEREFORE. pursua:llto 23 P.S. Section 1001 !;.\ ~., and other applicable rules
and law, the Plaintiff prays this Honorable Court to award custody of Ihe minor children to
him.
ROBERT C. RAMSEY, IN TilE COURT OF COMMON PLEAS
plaintiff
OF CUMBERLAND COUNTY
PENNSYLVANIA
vs. CIVIL ACTION - LAW
NO. 95-6062 CIVIL TERM
MARILYN S, RAMSEY, PROTECTION FROM ABUSE
Defendant AND CUSTODY
ORDER
1-\-\ \\
AND NOW, this llD day of \-\J I...~"v\-Q.'--; 1995, upon
Movant's Motion to Make Rule Absolute, it is hereby ordered and
decreed that stephen G. Held, Esquire, is released as counsel for
Marilyn Ramsey and has no further responsibility to represent the
Defendant in this matter,
BY TilE COURT:
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J.
rRUE COpy FROM RECOkU
. n T estlmony whereal. I here unto set my hand
IIld the seal 01 said Cou~. al Carlisle. ,,'
1 his -.I '. 1\ \ day ol~ I J" '. 19. "
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Prothonotlry
ROBERT C. RAMSEY, I IN THE COURT OF COMMON PLEAS
plaintiff I
I OF CUMBERLAND COUNTY
I PENNSYLVANIA
vs. I CIVIL ACTION - LAW
I NO. 95-6062 CIVIL TERM
MARILYN S. RAMSEY, : PROTECTION FROM ABUSE
Defendant AND CUSTODY
ORDER
AND NOW, this day of , 1995, upon
Movant's Motion to Make Rule Absolute, it is hereby ordered and
decreed that stephen G. Held, Esquire, is released as counsel for
Marilyn Ramsey and has no further responsibility to represent the
Defendant in this matter.
BY THE COURT:
J.
FilFn-Oo"iiCE
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ROBERT c. RAMSEY,
Plaintiff
IN TilE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
PENNSYLVANIA
CIVIL ACTION - LAW
NO. 95-6062 CIVIL TERM
PROTECTION FROM ABUSE
AND CUSTODY
vs.
MARILYN S. RAMSEY,
Defendant
RULE
AND NOW, this 4.::Ji... day of F'''r,~.l...."
1995, upon consideration of the foregoing petitioner and affidavit
and on motion of Stephen G. Held, Esq., the Court grants a Rule on
defendant and Austin Grogan, Esquire, attorney for plaintiff,
Robert C. Ramsey, to show cause why the appearance of Stephen G.
,~.
Ileld, Esq., attorney for d,fendant, shOUld/be withdrawn.
Rule returnable twenty (20) days after service.
By the Court:
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vs.
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
PENNSVLVANIA
CIVIL ACTION - LAW
NO. 95-6062 CIVIL TERM
PROTECTION FROM ABUSE
AND CUSTODY
ROBERT C. RAMSEVr
Plaintiff
MARILVN S. RAMSEV,
Defendant
CERTIFICATE OF SERVICE
I, Stephen G. Held, Esquire, hereby certify that on the date
set forth below I served a true and correct copy of the Motion to
Make Rule Absolute dated December JC , 1995, upon the following,
by First Class United States mail addressed as follows:
Marilyn Ramsey
35 Teaberry Drive
Carlisle, PA 17013
Dawn S. sunday, Esquire
39 West Main Street
Mechanicsburg, PA 17055
Date:.11{~1 '\ f
Austin F. Grogan, Esquire
24 North 32nd Street
camp Hill, PA 17011
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ROBERT C. RAMSEY,
plaintiff
V.
IN TilE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
MARILYN S. RAMSEY,
Defendant
PROTECTION FROM ARUSE
NO. 95-6062 CIVIL TERM
ORDER OF COURT
AND NOW, this 3rd day of November, 1995, the
court held a hearing on cross petitions filed by both parties
alleging abuse. After hearing the testimony of both the husband
and wife and also of Maribeth, 1 make the following findings on
the issue of abuse:
1. I find that Marilyn S. Ramsey has abused her
husband, Robert C. Ramsey, during the year 1995.
2. I find that Robert C. Ramsey has abused his wife,
Harilyn s. Ramsey, during the year 1995.
3. I also find that Marilyn S. Ramsey has abused her
daughter, Maribeth Ramsey, during the year 1995.
4. The Court directs that neither party shall abuse
or threaten to abuse or harass the other party for a period of
one year from this date.
5. There is a custody proceeding pending. Pending
further determinations on permanent custody, 1 a\.ard temporary
custody of Maribeth Ramsey to her father, Robert C. Ramsey. I
award temp"rary custody of catherine 11. Ramsey and Matthew P.
Ramsey to their mother, Marilyn S. Ramsey.
If the parties are not able to agree on partial
ROBERT C. IWISEY, I IN TilE COURT OF <:XX>lMON PLEAS OF
Plaintiff I CUMBERLAND COUNTY, PENNSYLVANIA
I
vs. I NO. 95-6062 CIVIL TERM
I
MARILYN S. RAMSEY, I CIVIL ACTION - LAW
Defendant I CUSTODY
CIUlBR Of' <Dm'
AND to/ this t, (r11
upon consideration of the sttached
is ordered and directed as follows:
day of j)L-u.,~ , 199",
Custody Conciliation Summary Report,~
1. The parties shall submit themselves and their minor Children to a
custody evaluation to be performed by Arnold Shienvold, Phd. Cost of the
evs1uation shall be shared equally by the parties. Upon the conclusion of
the evaluation and in the event the parties are not at that time able to
reach a permanent agreement on custody, either party may Petition the Court
to have this case again scheduled with the Custody Conciliator for a
Conference.
2. Pending further Order of this Court or agreement of the parties,
the Father shall have primary physical custody of Maribeth Ramsey (age 17)
and the Mother shall have primary physical custody of Matthew (age 14) and
Catherine Ramsey (age 8). The parties shall have shared legs 1 custody.
3. The Father shall have partial physical custody of Matthew and
Catherine Ramsey on alternating weekends from Thursday after school until
the following Monday morning. During weeks following weekends in which the
Mother had custody of Matthew and Catherine, the Father shall have partial
custody of the Children on Tuesday evening after school until 8130 p.m.
During weeks following weekends in which the Father had custody of Matthew
and Catherine, the Father shall have physical custody of the Children on
Thursday evening after school until B: 30 p.m. 'I'his alternating weekday
evening custody schedul~ shall begin on December 5, 1995. The Father's
alternating weekend custody schedule shall begin on December 7, 1995. The
Father shall have physical custody of the Children over the Christmas
holiday in 1995 from December 21 after school until December 24 at 12100
noon and from December 25 at 12:00 noon until December 26 at 12:00 noon.
4. The Mother shall have partial physical custody of Maribeth Ramsey
(age 17) as mutually agreed by the parties.
5. This Order is entered pursuant to an agreement of the parties at a
vs.
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
PENNSYLVANIA
CIVIL ACTION - LAW
NO. 95-6062 CIVIL TERM
PROTECTION FROM ABUSE
AND CUSTODY
ROBERT C. RAMSEY,
Plaintiff
MARILYN S. RAMSEY,
Defendant
PETITION TO WITHDRAW APPEARANCE
The Petition of stephen G. Held, Esq., respectfully
represents:
1. That on october 25, 1995, defendant and petitioner
entered into a fee agreement in which petitioner was retained to
represent defendant in a protection from abuse matter. Attached
as Exhibit "11" is a copy of the fee agreement.
2. That on october 31, 1995, petitioner filed an
answer and counterclaim alleging, inter alia, abuse of defendant
by plaintiff.
3. On or about November 2, 1995, and November 3/ 1995,
petitioner represented defendant in an evidentiary hearing on this
protection from abuse matter.
4. After that hearing, petitioner informed defendant
that, in order for him to continue the case, the substantial bill
for services outstanding from this hearing and another retainer,
would have to be paid by November 15, 1995.
5. As of this date, these terms have not been met.
6. lIddi tionally, defendant has refused on numerous
occasions to take the advice offered by petitioner.
7. Petitioner and defendant have failed to reach an
agreement on future representation.
B. Based upon information and belief, it is averred
that defendant has attempted to obtain successive counsel in order
to represent her in the custody action and may have at this time
secured successive counsel.
9. Petitioner wishes to terminate his professional
obligation to represent defendant in light of the failure to
negotiate a successive agreement for representation.
10. Petitioner herein wishes to be resolved of his
responsibility as counsel of record.
WHEREFORE, petitioner herein respectfully requests the
Court to allow his withdrawal as counsel without further
proceeding in this matter, and in the alternative to set a date
and time with the RUle Returnable from the defendant herein as to
why the requeet of the petitioner herein should not be granted.
Respectfully Submitted:
DISSINGER & DISSINGER
:itt6 -Ji tkk 9
Steph n G., Held, Esq.
Supreme Court 10/72663
28 North 32nd street
Camp Hill, PA 17011
(717)975-2840
Di~~ingtr
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Dissinger
lRttorntps lRt law
MARY A. ETTER DilliNGER
WILLIAM CHUTER DilliNGER
ITEPUEN GEOROE UUD
october 25, 1995
C.mp HIM OUlu:
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71707&.'840
rAil 717 076.3124
M.,y.vtll.Olflc.:
400 South 61.1' flold
MI,y,vill.. f'1tnn'ylll.nl. 17053
717 867.3474
rAil 717 017-2311
File 95-567
Ms. Marilyn Ramsey
35 Teaberry Drive
Carlisle, PA 17013
Dear Ms. Ram~ey:
You have asked our firm to represent you in a protection from
abuse action. This letter sets forth the agreement concerning our
representation of you and shall be effective upon receipt of the
retainer fee. We cannot undertake to do any work on your case until
we receive the enclosed agreement signed by you and the retainer in
the amount of $750.00. The retainer is a minimum fee and is not
refundable. In the event that your protection from abuse action is
not completed within the limits of this retainer fee, we will apply
the retainer fee to the work performed and bill you subsequently on
an hourly basis. Due to the nature of this matter and the
impossibility of determining what course the matter may take, we
are unable to establish a flat fee for our professional services.
Therefore, it is necessary to I'epresent you on an hourJy rate
basis. our billings are based on the present hourly rates set forth
in the attached fee schedule. Our hourly rates are adjusted every
January and whon the hourly rates are adjusted you will be
notified.
A
Our statements are generally premised upon the amount of
professional time expended by the attorneys and staff in our office
for such services as conferences, telephone conferences, research,
court appearances, travel and other miscellaneous legal services.
In addition, other considerations may e~ter into the setting of a
fee, such as: the novelty and difficulty of the issues involved;
the result achieved; the amount in dispute; the necessity of a
specialized skill requisite to perform the legal service properly;
the likelihood that the acceptance of a particular employment will
preclude other employment by the attorney; time limitations imposed
by the client or by the circumstances; the nature and length of the
professional relationship with the client; the area of law
involved; and the interruption of other work in progress.
It is impossible to determine in advance the amount of time
that will be needed to complete your case. We will keep you fully
informed of conferences, telephone calls, drafting of documents,
research, court time and necessary travel time.
Costs are our out-Of-pocket expenses, such as filing fees,
process server fees, transcripts, photocopies, long distance phone
calls, travel mileaga, investigators, appraisers and accountants.
Costs will also be itemized and billed on a periodic basis. We will
bill you monthly for legal services and costs and expect payment
within thirty (3D) days of the date of the bill.
We reserve the right to terminate our attorney-client
relationship for non-payment of fees or costs. We expect you to
keep current with our billings. If your retainer has been exhausted
and there is still considerable work to be done on your case, you
may be asked to replenish your retainer and costs before our legal
work continues.
We will keep you informed as to the progress of your case. We
will send you copies of all papers coming in and going out of our
offices, including correspondence, pleadings and other documents.
If we are unavai lilhle when you telephone, your call will be
returned with reasonable promptness. 'I~ere will be times when we
will be in Court or at meetings or in conference, which will
preclude us from returning your call as quickly as you might like,
but we shall do our best to return your telephone calls as we can.
lit such times, please feel confident to talk with our secretaries.
If you are passing on information, they can deliver it to us
without the necessity of your waiting to have us return the call.
If you have a question that requires an answer from us, it is far
easier for them to obtain the background from you, bring the matter
to our attention when we are free, and then have a response for
you. If it is necessary for you to speak with us directly, we will
attempt to leturn your call as soon as possible.
Every effort will be made to expedite your case promptly and
efficiently according to the highest legal and ethical standards.
Please acknowledge receipt of the enclosed agreement and your
acceptance of its terms by signing the enclosed copy and returning
it to us so that we will have a mutual memorandum of our
understanding. The other copy we have enclosed is for you to keep
for your records. We suggest that you keep your copy of the
engagement letter in the folder we have provided to you, along with
any future correspondence from this office. In addition, if you
ever have questions or comments for me in the future, you can write
them down on a piece of paper and sl ip that into tile folder for
reference the next time you correspond with or call our office.
Respectfully,
DISSINGER & DISSINGER
SGlllclb
lIccepted
I/YP
this ""..::J' day of
G. Held
, 1995.
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I ROBERT C. RAMSEY,
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IN THE COURT OF COMMON PLElIS
OF CUMBERLAND COUNTY
PENNSYLVANIA
CIVIL ACTION - LAW
NO. 95-6062 CIVIL TERM
PROTECTION FROM ABUSE
AND cUSTODY
MARILYN S. RAMSEY,
Defendant
ANSWER TO PLAINTIFF/S PETITION FOR PROTECTIVE ORDER
AND CUSTODY RELIEF UNDER THE PROTECTION FROM ABUSE ACT.
23 Pa. c.S.A. section 6101 et Bea.
the Defendant, Marilyn S.
& Dissinger, and answers as
Ramsey, by her
follows:
1.
Admitted.
2.
No response required.
3.
Admitted.
4.
Admitted.
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li 5. The statements of paragraph 5 are conolusions of law to
which no response is required. To the extent that it is doomod
factual in nature, it is hereby specifically donied thnt tho
Defendant has attempted to cause and has intentionally, knowingly,
or recklessly caused bodily injury or physicnl1Y nbused tho
plaintiff and his children.
a. Denied as stated.
shoved and pushed Maribeth Ramsey
Defendant used obscene language.
did spit in the minor's face, but
minor.
It is denied that Defendant
to the ground. It is denied
It is admitted that Defendant
it was after provocation by the
b. Denied as stated. It is admitted that on October
15, 1995, Defendant poured water on minor, Maribeth Ramsey. It is
denied that said water can be characterized as II ice water. II It is
denied that Defendant used obscene language. It is denied that
Defendant threw golf shoes at Plaintiff. To further clarify, it
was Plaintiff who threw the golf shoes at the Defendant. It is
admitted that Defendant clipped off roses in Plaintiff/s flower
garden. It is denied that Defendant's actions placed the
Plaintiff in imminent abuse and it is denied that such actions
could be construed as carried out in a "threatening manner." It
is denied that the Defendant hit Plaintiff in the right eye. It
is denied as stated that Defendant punched and kicked at
Plaintiff / s groin. To further clarify, Defendant punched and
kicked at Plaintiff's groin in an attempt to free herself from
Plaintiff's attack, in which he was grabbing her by the hair and
holding her head on the ground. It is denied that Defendant cut
off a piece of Plaintiff's hair with a pair of scissors. It is
denied that Defendant dragged Plaintiff around the living room by
his hair. It is denied that Defendant picked the lock of the
bedroom door and continued to hit and kick Plaintiff. It is
denied that Defendant broke the door from the hinges and out of
the frame. To further clarify, the door was already off its
hinges because Plaintiff had in the past hit Defendant's head
against the door, putting a hole in the door. Plaintiff broke the
hinges himself when he propped up the door. In addition, the door
already had been damaged in the past when Plaintiff had hit
Defendant's head against the door. It is denied that Defendant
began hitting Plaintiff with the door as he lay on the bed.
c.
lIdmitted in part and denied
on September 9, 1995, the police
in part. It is
were called to the
admitted that
parties' residence. It is denied that Defendant had been hitting
Plaintiff. On the contrary, it was Plaintiff who was hitting
Defendant. It is admitted that the Defendant hit the minor child,
Matthew Ramsey, in the mouth. However, it is denied that such a
hit caused the minor's mouth to bleed. To further clarify,
Defendant slapped Matthew Ramsey/s face after he had been back-
talking Defendant and it was a light slap in an effort to
discipline. It is admitted that Plaintiff attempted to record
statements by the Defendant against her consent. It is denied
that statements of the Defendant could be characterized as
"rantings." It is admitted that Defendant attempted to gain the
recorder. It is admitted that Plaintiff put the recorder in his
jeans and it is admitted that the Defendant cut open his jeans in
an attempt to obtain the recorder. To further clarify, Plaintiff
had put the recorder down his pants after taping Defendant without
her consent. Then Defendant stated to plaintiff that she wanted
the recorder and that she would cut his pants to get it. He then
said, "Go ahead" and stood in front of Defendant, whereupon
Defendant did cut open his jeans.
d. Denied. It is denied that on February 17, 1995,
Defendant abused the minor chi ld, Maribeth Ramsey, and it is
denied that Defendant punched Maribeth Ramsey in the face.
e. lIdmitted in part and denied in part. It is
admitted upon information that on January 16, 1995, the police
were called to the parties' residence. It is denied that
Defendant again struck the minor, Maribeth Ramsey. To further
clarify, on that date Dofendant was handl ing a bookbag which
belonged to the minor, Maribeth Ramsey, in an attempt to clean
some spillage contained within the bag. Maribeth Ramsey grabbed
the bag and started to run with Defendant's fingers caught in the
bag. Defendallt freed herself with an upward jerk, causing her
wrist to hit Maribeth's jaw. In turn, Plaintiff then hit
Defendant, causing bruising on various parts of Defendant/s body.
After Plaintiff took Maribeth Ramsey to the hospital for an
examination of her jaw, of which no damage was found, Defendant
called the police herself. She had to lift her shirt to reveal
i her injuriee to the responding officers and Detective Johnson
stated that if Mr. Rameey returned while he was there, Mr. Ramsey
would be arrested. Charges were pressed against both Defendant
and Plaintiff, although the charges against Mr. Ramsey were
subsequently dropped by Defendant.
6. Denied as stated. It is admitted that on October 16,
1995, Plaintiff and Maribeth Ramsey left the residence at 35
Teaberry Drive, Carlisle, Middlesex Township, Cumberland County,
Pennsylvania. It is denied that such actions were to avoid
further abuse.
7. The allegations of Paragraph 7 are a conclusion of law
to which no response is required. To the extent it may be deemed
factual, it is hereby denied that Plaintiff and his children will
be in immediate and present danger from abuse from Defendant. It
is further denied that Plaintiff and his children are in need of
protec~ion from such abuse.
B. The allegations of Paragraph B are a conclusion of law
to which no response is required. To the extent it may be deemed
factual, Defendant is without knowledge as to the desiree of
Plaintiff.
9. The allegations of Paragraph 9 are a conclusion of law
to which no response is required. To the extent it may be deemed
factual, it is denied that Defendant has used or threatened to use
any weapons, and it is further denied that Defendant ever abused
Plaintiff.
B. TEMPORARY CUSTODY
10. Admitted.
11. Admitted.
12. The allegations of paragraph 12 are a conclusion of law
to which no response is required. To the extent it may be deemed
I
factual, Defendant is without knowledge as to the knowledge of
Ii
plaintiff regarding custody proceedings.
13. The allegations of Paragraph 13 are a conclusion of law
to which no response is required. To the extent it may be deemed
factual, Defendant is without knowledge as to the knowledge of
Plaintiff regarding 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.
14. The allegations of Paragraph 14 are a conclusion of law
to which no responsive pleading is required. To the extent it may
be deemed factual, it specificallY denied that the best interests
and permanent welfare of the children will only be met if custody
is temporarilY granted to the Plaintiff.
a. It is denied that Plaintiff is a fit parent who can
best take care of his children.
b. It is denied that the Defendant has shown any
abuse.
c. It is denied that the Defendant is an unfit parent.
c. EXCLUSIVE POSSESSION
15.
Admitted.
16.
Plaintiff
is denied
Denied as stated. It is admitted upon information that
owns no other property within this state. However/ it
that plaintiff has no place to stay.
4. On various dates, Plaintiff/counter-defendant has
participated in inappropriate behaviors such as throwing things,
slamming doors, and even breaking a hole in the master bedroom
door. one of the items which was thrown was the sewing machine
belonging to Defendant/counter-plaintiff, which was dropped on the
floor and broken.
5. On one date, Plaintiff/counter-defendant verbally
harassed Defendant/counter-plaintiff and he recorded her with a
video camera as part of the ongoing verbal harassment.
6. On numerous occasions, Plaintiff/counter-defendant has
been observed by the minor children of the parties while using
profane language towards and hitting and pushing
Defendant/counter-plaintiff.
7. On March 4, 1995, Plaintiff/counter-defendant and
Defendant/counter-plaintiff were arguing in their bedroom. Mr.
Ramsey was sitting on the bed and Ms. Ramsey reached across him to
get a pair of glasses. Plaintiff/counter-defendant jumped up and
immediately strur.k Defendant/counter-plaintiff in the right eye,
reSUlting in a bruised, black eye.
B. On August 27, 1995, Defendant/counter-plaintiff was in
the kitchen and Plaintiff/counter-defendant entered the kitchen.
For reasons unknown to Defendant/counter-plaintiff, Mr. Ramsey was
very angry. Ms. Ramsey had a fork in her hand at the time and Mr.
Ramsey asked her loudly, "What are you going to do, stab me with
that fork?" He then picked up the Defendant/counter-plaintiff and
threw her against the refrigerator, causing her to land on the
floor on her left knee. Ms. Ramsey's knee, left thigh, and the
left side of her chin sustained bruises and she was forced to seek
aid at the carlisle Domestic Violence Shelter. said injuries were
observed at that time by Or. Heidi L. Joos, MD., Jessica Hart, MA,
and a woman named Lois at the Shelter.
9. In the evening of August 31, 1995, Defendant/counter-
plaintiff and Plaintiff/counter-defendant had an argument. Mr.
Ramsey puehed Ms. Ramsey, causing her to fall backward into her
chair and her arm scraped the corner of the wall. This resulted
in a scrape and a lump on Defendant/counter-plaintiff's arm.
Plaintiff/counter-defendant then twisted Ms. Ramsey/s right
forearm and pulled her down until she was on her knees. This
altercation was observed by the minor child, Maribeth Ramsey, who
asked her father to stop. These injuries were observed by Dr.
Heidi L. Joos, MD. and Jessica Hart, MA.
10. On October 27, 1995, Plaintiff/counter-defendant came to
the marital residence with the intent of taking the minor child,
Catherine Ramsey, by force, after he had filed his Petition for
Protection from Abuse from Defendant/counter-plaintiff. He
physically assaulted Ms. Ramsey at this time and the police were
called to the scene. Mr. Ramsey also put her in fear of imminent
bodily injury.
WHEREfORE, the Defendant/counter-plaintiff requests that this
Honorable Court enter a Protection From lIbuse Order:
A. Excluding Plaintiff/counter-defendant from the marital
residence at 35 Teaberry Drive, CarliSle, Cumberland County,
Pennsylvania and from any other residence Defendant/counter-
plaintiff might choose to establish;
B. Directing Plaintiff/counter-defendant to cease and
desist attempts to contact or visit Defendant/counter-plaintiff by
telephone or otherwise, to refrain from being in the physical
presence of Defendant/counter-plaintiff pending final hearing and
then for a period o( time not to exceed one year;
C.
Directing Plaintiff/counter-defendant to
threatening, harassing or verbally
cease and
abusing
desist
,
,.
VERIFICATION
,j
I verify that the statements made in the foregoing document
are true and correct. I understand that false statements herein
are made subject to the penalties of 18 Pa.C.S. 4904, relating to
i unsworn falsification to authoritiee.
<}j, ({~
amsey / D fen_aC)
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ROBERT C. RAMSEY,
Ii Plaintiff
IN TIlE COURT OF COMMON PLEAS
VB.
'I' MARILYN S. RAMSEY,
Defendant
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!
OF CUMBERLAND COUNTY
PENNSYLVANIA
CIVIL ACTION - LAW
NO. 95-6062 CIVIL TERM
PROTECTION FROM lIBUSE
AND CUSTODY
CERTIFICATE OF SERVICE
I, stephen G. Held, Esquire, hereby certify that on the date
Bet forth below I served a true and correct copy of the foregoing
document upon the attorney for the Plaintiff, by hand delivery to
the address as follows:
lIustin F. Grogan, Esquire
24 North 32nd street
Camp Hill, PlI 17011
Datel~
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, J,
Stephe G. Held,
f~tQ
Esquire
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ROBERT c. RAMSEY,
Plaintiff
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
PENNSYLVANIlI
CIVIL lICTION - LlIW
NO. 95-6062 CIVIL TERM
PROTECTION FROM ABUSE
AND CUSTODY
vs.
MARILYN s. RAMSEY,
Defendant
ANSWER TO PLAINTIFF'S PETITION FOR PROTECTIVE ORDER
AND CUSTODY RELIEF UNDER THE PROTECTION FROM ABUSE ACT.
23 Pa. c.S.A. section 6101 et sea.
AND NOW, comes the Defendant, Mari lyn S. Ramsey, by her
attorneys, Dissinger & Dissinger, and answers as follows:
1. lIdmi tted.
2. No response required.
J. lIdmitted.
4. Admitted.
5. The statements of Paragraph 5 are conolusions of law to
which no response is required. To the extent that it is deemed
factual in nature, it is hereby specifically denied that the
Defendant has attempted to cause and has intentiona 11)', knowingly,
or reckleBsly caused bodily injury or physically abused the
plaintiff and his children.
a.
Denied Ole atated.
It is denied that Defendant
to the ground. It is denied
It is admitted that Defendant
it was after provocation by the
ehovod and pushed Mnrlbeth Homeey
Defendant used obscene language.
did Bpit in the minor'B face, but
minor.
b. Denied as stated. It is admitted that on October
15, 1995, Defendant poured wilte," on minor, Mar-ibeth Ramsey. It is
denied that said water can be charilcterized as "ice water." It is
denied that Defendant used obscene language. It is denied that
Defendant threw golf shoes at Plaintiff. To further clarifY, it
was Plaintiff who threw the golf shoes at the Defendant. It is
admitted that Defendant clipped ofl 1-013<''' in Plaintiff's flower
garden. It is denied th,~t Defendant's actions placed the
Plaintiff in imminent abuse i1nd it is doniml that such actions
could be construed as carried out in a "threatening manner." It
is denied that the Defendant hit Plaintiff in the right eye. It
is denied as stated that Defendant punched and kicked at
Plaintiff's groin. '1'0 further clarify, Defendant punched and
kicked at Plaintiff's groin in an attempt to free herself from
Plaintiff's attack, in which he was grabbing her by the hair and
holding her head on the ground. It is denied that Defendant cut
off a piece of Plaintili's hair with a pair 01 sciusors. It is
denied that Defendant dragged Plaintiff around the living room by
his hair. It is denied that Defendant picked the lock of the
bedroom door and continued to hit and kick Plaintiff. It is
denied thilt Def endant broke the door 1 rom tho hinges and out of
the frame. '1'0 fUI"tller clarifY, the dool" W;\B already oft its
hinges becmlBe Plaintiff had In the pilnt hit Defendant's head
against the door, puttin'J a hole In the door. Plaintiff broke the
hinges himself when he propped up the door. In addition, the door
already had been damaged in the past when Plaintiff had hit
Defendant's head against the dool". It is denied that Uefendant
began hittin<j Plaintill with the door aB he l,~y on the bed.
c. Admitted In part and denied In IJolrt. It is
,~dmitted thilt on fieptember 'J, I'J'J!J, the pol ice were called to the
parties' residence. It is denied that Defendant had been hitting
Plaintiff. On the contrary, it was Plaintiff who was hitting
Defendant. It is admitted that the Defendant hit the minor child,
Matthew RamseY, in the mouth. However, it is denied that such a
hit caused the minor's mouth to bleed. 1'0 further clarify,
Defendant slapped Mntthew Ramsey's face after he had been back-
talking Defendant and it was a light slap in an effort to
discipline. It is admitted that Plaintiff attempted to record
statements by the Defendant against her consent. It is denied
that statements of the Defendant could be characterized as
"rantings." It is admitted that Defendant attempted to gain the
recorder. It is admitted that Plaintiff put the recorder in his
jeans and it is admitted thnt the Defendant cut open his jeans in
an attempt to obtain the recorder. To further clarify, Plaintiff
had put the recorder down his pants after taping Defendant without
her consent. Then Defendant stated to plaintiff that she wanted
the recorder and that she would cut his pants to get it. He then
said, "Go ahead" and stood in front of Defendant, whereupon
Defendant did cut open his jeans.
d. Denied. It is denied that on February 17, 1995,
Defendant abused the minor child, Maribeth Hamsey, and it is
denied that Defendant punched Maribeth Ramsey in the face.
e. Admitted in part and denied in part. It is
admitted upon information that on January 16, 1995, the police
were called to the parties' residence. It is denied that
Defendant again struck the minor, Maribeth Ramsey. To further
clarify, on that date Defendant was handling a bookbag which
belonged to the minor, Maribeth Ramsey, in an attempt to clean
some spillage contained within the bag. Maribeth Ramsey grabbed
the bag and started to run with Defendant's fingers caught in the
bag. Defendant freed hel"Self with an upward jerk, causing her
wrist to hit Maribeth's jaw. In turn, plaintiff then hit
Defendant, causing bruising on various parts of Defendant's body.
After Plaintiff took Mndbeth HamseY to the hospital for an
examination 01 her jaw, 01 which no damage was found, Defendant
called the police herself. She had to lift her shirt to reveal
her injuries to the responding officers and Detective Johnson
stated that if Mr. Ramsey returned while he was there, Mr. Ramsey
would be arrested. Charges were pressed against both Defendant
and Plaintiff, although tho charges against Mr. Ramsey were
subsequently dropped by Defendant.
6. Denied
1995, Plaintiff
Teaberry Drive,
Pennsylvania.
further abuse.
as stated. It is admitted that on October 16,
and Maribeth Ramsey left the residence at 35
Carlisle, Middlesex Township, Cumberland County,
It is denied that such actions were to avoid
7. The allegations of Paragraph 7 are a conclusion of law
to which no response is required. To the extent it may be deemed
factual, it is hereby denied that Plaintiff and his children will
be in immediate and present danger from abuse from Defendant. It
is further denied that Plaintiff and his children are in need of
protection from such abuse.
B. The allegations of Paragraph B are a conclusion of law
to which no response is required. To the extent it may be deemed
factual, Defendant is without knowledge as to the desires of
Plaintiff.
9. The allegations of Paragraph 9 are a conclusion of law
to which no response is required. To the extent it may be deemed
factual, it is denied that Defendant has used or threatened to use
any weapons, and it is further denied that Defendant ever abused
Plaintiff.
B, TEMPORARY CUSTODY
10. Admitted.
11. Admitted.
12. The alleg~tions of paragraph 12 are a conclusion of law
to which no response is required. To the extent it may be deemed
factual, Defendant is without knowledge as to the knowledge of
Plaintiff regarding custody proceedings.
13. The allegations of Paragraph 13 are a conclusion of law
to which no response is required. To the extent it may be deemed
factual, Defendant is without knowledge as to the knowledge of
Plaintiff regarding any person not a party to this action who has
physic~l custody of the children or claims to have custody or
visitation rights with respect to the children.
14. The allegations of Paragraph 14 are a conclusion of law
to which no responsive pleading is required. To the extent it may
be deemed factual, it specifically denied that the best interests
and permanent welfare of the children will only be met if custody
is temporarily granted to the plaintiff.
a. It is denied that plaintiff is a fit parent who can
best take care of his children.
b. It is denied th~t the Defendant has shown any
abuse.
c. It is denied that the Defendant is an unfit parent.
c. EXCLUSIVE POSSESSION
15.
Adm i tted .
16.
Plaintiff
is denied
Denied as stated. It is admitted upon information that
owns no other property within this state. Ilowever, it
that Plaintiff has no place to stay.
4. On vadous datl.!s, Plaintif1/counter-defendant has
participated in inappropriate behaviors such as throwing things,
slamming doors, and even breaking a hole in the master bedroom
door. One of the items which was thrown was the sewing machine
belonging to Defendant/counter-plaintiff, Which was dropped on thl.!
floor and broken.
5. On one date, Plaintiff/counter-defendant verbally
harassed Defendant/counter-plaintiff and he recorded her with a
video camera as part of the ongoing verbal harassment.
6. On numerous occasions, Plaintiff/counter-defendant has
been observed by the minor children of the parties while using
profane language towards and hitting and pushing
Defendant/counter-plaintiff.
7. On March 4, 1995, Plaintiff/counter-defendant and
Defendant/counter-plaintiff were arguing in their bedroom. Mr.
Ramsey was sitting on the bed and Ms. Ramsey reached across him to
get a pair of glasses. Plaintiff/counter-defendant jumped up and
immediately struck Defendant/counter-plaintiff in the right eye,
reSUlting in a bruised, black eye.
B. On lIugust 27, 1995, Defendant/counter-plaintiff was in
the kitchen and Plaintiff/counter-defendant entered the kitchen.
For reasons unknown to Defendant/counter-plaintiff, Mr. Ramsey was
very angry. Ms. Ramsey had a fork in her hand at the time and Mr.
Ramsey asked her loudly, "What are you going to do, stab me with
that fork?" lie then pickl.!d up till.! Defendant/counter-plaintiff and
threw her against thl.! rl.!1rigerator, causing her to land on the
floor on her ll.!ft knl.!e. Ms. Ramsl.!Y's knee, left thigh, and the
left side of hl.!r chin sustained bruises and she was forced to seek
aid at thl.! Carlisle Domestic Violl.!ncl.! Sheltl.!r. Said injuries were
observed at that time by Dr. Ileidi L. Joos, MD., Jessica Hart, MA,
and a woman naml.!d Lois at the Shelter.
9. In the evening of lIugust 31, 1995, lJofendant/counter-
plaintiff and Plaintiff/counter-defendant had an argument. Mr.
Ramsey pushed Ms. Ramsey, causing her to fall backward into her
chair and her arm scraped the corner of the wall. This resulted
in a scrape and a lump on Defendant/counter-plaintiff's arm.
Plaintiff/counter-defendant then twisted Ms. Ramsey's right
forearm and pulled her down until she was on her knees. This
altercation was observed by the minor child, Maribeth Ramsey, who
asked her father to stop. 'I~ese injuries were observed by Dr.
Heidi L. Joos, MD. and Jessica Hart, MA.
10. On October 27,1995, Plaintiff/counter-defendant came to
the marital residence with the intent of taking the minor child,
Catherine Ramsey, by force, after he had filed his Petition for
Protection from Abuse from Defendant/counter-plaintiff. He
physically assaulted Ms. Ramsey at this time and the police were
called to the scene. Mr. Ramsey also put her in fear of imminent
bodily injury.
WHEREFORE, the Defendant/counter-plaintiff requests that this
Honorable Court enter a Protection From Abuse Order:
11. ExclUding Plaintiff/counter-defendant from the marital
residence at 35 'I'eaberry Drive, Carlisle, cumberland County,
Pennsylvania and from any other residence Defendant/counter-
plaintiff might choose to establiSh,
B. Directing Plaintiff/counter-defendant to cease and
desist attempts to contact or visit Defendant/counter-plaintiff by
telephone or otherwise, to refrain from being in the physical
presenco of Defendant/counter-plaintiff pending final hearing and
then for a period of time not to exceed one yea.";
C.
lJiI.octing Plaintiff/counter-defendant to ceaee and
threatening, harassing or verbally abusing
desist
('f'
rk
ROBERT C. RAMSEY,
plaintiff
IN 'I'IIE coUR'I' OF COMMON PLEAS
vs.
of CUMBERLAND COUNTY
PENNSYINANIlI
CIVIL lICTION - LAW
NO. 95-6062 ClVIL TERM
PROTECTION moM lIBUSE
AND CUSTODY
MARILYN B. RAMSEY,
Defendent
PRELIMINARY ORDER OF COURT
AND NOW, this _ day of
consideration of the within lInswer and counterclaim,
ORDERED, lIDJUDGED, AND DECREED as followSI
1995,
it is
after
hereby
1. plaintiff /counter-defendant is prel iminarily enjoined
from appearing at, entering, or trespassing at wherever
Defendant/counter-plaintiff may be temporarily residing, pending
a final hearing.
2. Plaintiff/counter-defendant is preliminarilY enjoined
from attempting to contact or visit with Defendant/counter-
plaintiff by telephone or otherwise, and is restrained from being
in the physical presence of Defendant/counter-plaintiff, pending
a final hearing.
J. Plaintiff/counter-defendant is preliminarilY enjoined
from threatening or harassing Defendant/counter-plaintiff in any
manner, including over the telephone, pending a final hearing.
4. 'rhe fiMl hearing is to be held on this petition, as
follOWS I
Datel November 2, 1995
place I courtroom No.
Carlisle, PlI 17013.
Time: 1130 p.m.
1, cumberland county courthouse,
a. Deni<!d as stat<!d.
It is denied that Defendant
to th<! ground. It is denied
It is admitted that Defendant
it was after provocation by the
shoved and pushed Maribeth Ramsey
Defendant used obsc<!ne language.
did spit in the minor's face, but
minor.
b. D<!nied as stated. It is admitted that on October
15, 1995, Defendant poured water on minor, Maribeth Ramsey. It is
denied that said water can be characterized as "ice water." It is
denied that Defendant used obscene language. It is denied that
Defendant threw golf shoes at Plaintiff. To further clarify, it
was Plaintiff who threw the golf shoes at the Defendant. It is
admitted that Def<!ndant clipp<!d off ros<!s in Plaintiff's flower
garden. It is denied that De[<!ndant's actions placed the
Plaintiff in imminent abus<! and it is denied that such actions
could be construed as carried out in a "threatening manner." It
is denied that the Defendant hit Plaintiff in the right eye. It
is denied as stated that Defendant punched and kicked at
Plaintiff's groin. To further clarify, Def<!ndant punched and
kicked at Plaintiff's groin in an attempt to free herself from
Plaintiff's attack, in which he was grabbing her by tho hair and
holding her head on the ground. It is deni<!d that Defendant cut
off a piece of Plaintiff's hair with a pair of scissors. It is
denied that Def<!ndant dragged Plaintiff around th<! living room by
his hair. It is denied that D<!fendant picked the lock of the
bedroom door and continu<!d to hit and kick Plaintiff. It is
denied that lJ<!f<!ndant bl"ok<! tlj(! doO!" from tlw hing<!s and out of
tll<! fram<!. To fUI"th<!l" clarify, the door was already off its
hinges b<!caus<! Plaintifl had in the past hit Defendant's head
against t1w dOOI", puttin<J ., hol<! in the dool". Plaintiff bl-oke the
hinges hi mse If when he propp<!d up the door. In add i ti on, t1w d001-
already had been damaged in the past when Plaintiff had hit
Defendant's hend against the door. It is denied that Defendant
began hittll1<j Plaint! (1 with tho doO!" 11S he Iny on the bed.
c. Admitted In part and denied in part. It is
ndmltted thnt on BeptombUl" 'I, I~JY!), the pollc" w"r" call"cl to the
parties' residence. It is denied thot Defendant had been hitting
Plaintiff. On the contrary, it was Plaintiff who was hitting
Defendant. It is admitted that the Defendant hit the minor child,
Matthew Ramsey, in the mouth. However, it is denied that such a
hi t caused the mi nor's mouth to bleed. 'I'o further clar i fy,
Defendant slapped Matthew Homsey's face after he had been back-
talking Dcfendant and it was a I ight slap in an effort to
discipline. It is admitted that Plaintiff attempted to record
statements by the Defendant against her consent. It is denied
that statements of the Defendant could be characterized as
"rantings." It is admitted that Defendant attempted to gain the
recorder. It is admitted that Plaintiff put the recorder in his
jeans and It is admitted that the Defendant cut open his jeans in
an attempt to obtain the recorder. To further clarify, Plaintiff
had put the recorder down his pants after taping Defendant without
her consent. Then Defendant stated to Plaintiff that she wanted
the recorder and that she would cut his pants to get it. He then
said, "Go ahead" and stood in front of Defendant, whereupon
Defendant did cut open his jeans.
d. Denied. It is dcnied that on February 17, 1995,
Defendant abused the minor child, Maribeth Hamsey, and it is
denied that Deiendant punched Maribeth Ramsey in the face.
e. lIdmltted in part and denied in part. It is
admitted upon information thilt on January 10, 1995, the police
were called to the parties' residence. It is denied that
Defendant aga in strud: the mi 1101-, Milrl beth Hilmsey. To further
clarify, on that dilte lJef"ndant WiW hilnclJ I ng il bookbag which
belonged to the minor, Maribeth Ililmney, in iln attempt to cleiln
some spillage contained within till' bag. Maribeth Hamsey g,-abbed
the bag and start"d to run with lJefendant'n fingers caught in the
bag. Defendant freed hel-nelf with iln upwilnl jerk, cilusing her
wrist to hit Madbelh's jaw. In tunl, plaintiff then hit
Defendant, causing bruising on various parts of Uefendant's body.
After plaintiff took ~ladboth Ilanuwy to the hospitill fOI- an
examination of )wr jaw, of which no damage was found, Defendant
ca lIed the pol ice herself. she had to I ift her shirt to reveal
her injuries to the responding officers and Detective Johnson
stated that if Mr. Ramsey returned while he was there, Mr. Ramsey
would be arrested. Charges were pressed against both Defendant
and Plaintiff, although the charges against Mr. Ramsey were
subsequently dropped by Defendant.
6. Denied as stated. It is admitted that on October 16,
1995, Plaintiff and Maribeth Ramsey left the residence at 35
Teaberry Drive, carlisle, Middlesex Township, Cumberland County,
Pennsylvania. It is denied that such actions were to avoid
further abuse.
7. The allegations of Paragraph 7 are a conclusion of law
to which no response is required. To the extent it may be deemed
factual, it is hereby denied that Plaintiff and his children will
be in immediate and present danger from abuse from Defendant. It
is further denied that Plaintiff and his children are in need of
protection from such abuse.
B. The allegations of Paragraph B are a conclusion of law
to which no responEe is required. To the extent it may be deemed
factual, Defendant is without knowledge as to the desires of
Plaintiff.
9. The allegations of Paragraph 9 are a conclusion of law
to which no response is required. To the extent it may be deemed
factual, it iE denied that Defendant has used or threatened to use
any weapons, and it is further denied that Defendant ever abused
Plaintiff.
Di_~~nnRY CUSTODY
10. lIdmitted.
4. On various dates, Plaintifl/counter-detendant has
participated in inappropriate behaviors such as throwing things,
slamming doors, and even breaking a hole in the master bedroom
door. One of the items which was thrown was the sewing machine
belonging to Defendant/counter-plaintiff, which was dropped on the
floor and broken.
5. on one date, Plaintiff/counter-defendant verbally
harassed Defendant/counter-plaintiff and he recorded her with a
video camera as part of the ongoing verbal harassment.
6. on numerous occasions, Plaintiff/counter-defendant has
been observed by tho minor children of the parties while using
profane language towards and hitting and pushing
Defendant/counter-plaintiff.
7. On March 4, 1995, Plaintiff/counter-defendant and
Defendant/counter-plaintiff were arguing in their bedroom. Mr.
Ramsey .Ias sitting on the bed and Ms. Ramsey reached across him to
get a pair of glasses. Plaintiff/counter-defendant jumped up and
immediately struck Defendant/counter-plaintiff in the right eye,
reSUlting in a bruised, black eye.
B. On August 27, 1995, Defendant/counter-plaintiff was in
the kitchen and Plaintiff/counter-defendant entered the kitchen.
For reasons unknown to Defendant/counter-pln i ntiff, Mr. Ramsey was
very angry. Ms. Hamsey had a fork in her hand at the time and Mr.
Ramsey asked her loudly, "What are you going to do, stab me with
that fork?" He then picked up the Def(!lldant/counter-plaintiff and
threw her aga i nst tho I'of ri qerator, caus ing her to land on the
floor on her loft kneo. Ms. Homsey's knee, left thigh, and the
left side of her chin sustained bruises and she was forced to seek
aid at the carlisle Domestic Violence shelter. Said injuries were
observed at that time by Dr. Heidi L. Joos, MD., Jessica Hart, MlI,
and a woman nilmod Lois nt the sholto,'.
9. In the evening of lIugust 31, 1995, Defendant/counter-
plaintiff and Plaintiff/counter-defendant had an argument. Mr.
Ramsey pushed Ms. Ramsey, causing her to fall backward into her
chair and her arm scraped the corner of the wall. 'I'his resulted
in a scrape and a lump on Defendant/counter-plaintiff's arm.
Plaintiff/counter-defendant then twisted Ms. Ramsey's right
forearm and pulled her down until she was on her knees. This
altercation was obsel'ved by the minor child, Maribeth Ramsey, who
asked her father to stop. These injuries were observed by Dr.
Heidi L. Joos, MD. and Jessica Hart, MA.
10. On October 27, 1995, Plaintiff/counter-defendant came to
the marital residence with the int~nt of taking the minor child,
catherine Ramsey, by force, after he had filed his Petition for
protection from lIbuse from Defendant/counter-plaintiff. He
physically assaulted Ms. Ramsey at this time and the police were
called to the scene. Mr. Ramsey also put her in fear of imminent
bodily injury.
WHEREFORE, the Defendant/counter-plaintiff requests that this
Honorable Court enter a Protection From lIbuse Order:
11. Excluding Plaintiff/counter-defendant from the marital
residence at 35 'I'eaberry Drive, carlisi", cumberland county,
Pennsylvania and from any other residence Defendant/counter-
plaintiff might choose to establish;
B. Directing Plaintiff/counter-defendant to cease and
desist attempts to contact or visit Defendnnt/counter-plaintiff by
telephone or otherwise, to refl-nin from being in the physical
presence of Defendant/counter-plaintiff pending final hearing and
then for a period of time not to exceed one yenr;
c.
Directing Plaintiff/counter-defendant to cease and
threatening, harassing or v"rbally abusing
desist
It ill denied lIlilt IJulundant.
to t.he IJI-oun<!. It. III dunilld
It ill ndmitted 1I1l1t: IJnfelulnnt
it wns af tl!r provocati on by the
n. Uenied nu lIt.llted.
uhoved nnd pushed Mnribllth Hamuey
Defendant used obscenll InnyunYl!.
did apit in the minor's fnce, but
minor.
b. Uenilld nu statl!d. It is admittl!d thnt on octobl!r
15, 1995, Defendant poured wnt",' on minor, Madbeth Hnmsoy. It is
denied thnt naid water con be characterizl!d an "ice wnter." It is
denied that Uefendant used obscl!'w lan<juage. It is dl!nied that
Defendant thrl!w golf shoes at rlaintiff. To further clarifY, it
was Plaintiff who thl'ew the golf ShOllS at till! Defendant. It is
admitted that. lJefl!ndant. dipped 01 t 1-06"" in Plaintiff'n flower
garden. It is dl!nied that Delend'll1t's actions placed the
Plaintiff in imminent abuse and it. i6 denied that such actions
could be construed as carried out in a "threatening manner." It
is denied that the Uefendant hit Plaintiff in the right eye. It
is denied as stated that Defendant punched and kicked at
Plaintiff's groin. To fUI-tlwl" dadfy, Defl!ndant punchl!d and
kicked at Plaintiff's groin in an attempt to frl!e herself from
Plaintiff's attack, in which he wan gl"abbing her by the hail" and
holding her head on the gl-ound. It is den i ell that Defendant cut
off a piece of Plaintiff's hair with a pair of scissors. It is
denied that Uefl!ndant dragged Plaintiff around the living room by
his hair. It is denied that Defendant picked the lock of the
bedroom door and continued to hit and ~:ick Plaintiff. It is
denied that Defendant broke the door from the hinges and out of
the frame. '1'0 furt.her- clarify, t.he dool- wan all"eady off its
hinges becnuse Plaintif f had in tho past. hit Uefendant's head
against the dOOI-, pUt.tinlJ a hol" in the dool". Plaintiff broke the
hinges hi lOse I f when he IJl'Oppl!d up t.he door. I n add i t I on, the doot"
already had bel!n damaged in till! past when plaintiff had hit
Defendant's head ayalnnt thl! dool". It is denied that Defendant
began hittintl Plaintifl with till! dool- all he lay on tlw bed.
c.
lIdmitted in part and denied
on I;ept.l!mlll"- 9, I'J'J~. the polic"
I t is
in part.
admitt.ed lIliIt
were called to the
pill,ties' residence. It in deniml thnt Dolellllant hold been hitting
Plaintiff. on the contrary, it wnD plnintifl who WnD hitting
Defendant. It is admitted that the Defendnnt hit the minor child,
Matthew Ramsey, in the mouth. However, it is denied that ouch n
hit caused the minor's mouth to bleed. '1'0 fUt-ther c!nrify,
Defendant slapped Matthew ~nmsey's fnce nfter he had been bnck-
talking Defendnnt nnd it was a light slap in an effort to
discipline. It is ndmitted thnt Plaintiff nttempted to record
statements by the Defendant ngai nst her consent. It is denied
that statements of the Defendant could be characterized as
"rantings." It is admitted that Defendant attempted to gain the
recorder. It is admitted that Plaintiff put the recorder in his
jeans and it is admitted that the Defendant cut open his jeans in
an attempt to obtain the recorder. To further clarify, Plaintiff
had put the recorder down his pants after taping Defendant without
her consent. 'I~en Defendant stated to Plaintiff that she wanted
the recorder and that she would cut hiD pants to get it. He then
said, "Go ahead" and stood in front of Defendant, whereupon
Defendant did cut open his jeans.
d. Denied.
Defendant abused the
denied that Defendant
It is denied that on
minor child, Maribeth
punched Maribeth ~amsey
February 17,
~amsey, and
in the face.
1995,
it is
e. Admitted in part and denied in part. It is
admitted upon infOl'mation that on ,January 16, 1995, the police
were called to the pat'tieG' n!sidence. It is denied that
Defendant again strud: the minot', Maribeth Hamsey. '1'0 further
clarify, on that date (Jpfen<lilnt WaS handling a bookbag which
belonged to the minor, Madl",th ~am[ley, in an nttempt to clean
some spill age cant a i Iled wi th I n the bag. Milriheth Hamsey grabbed
the bag and Gtarte<l to 1'11/1 with (Jefendant's fin<jers caught in the
bag. Defendant In>l'<I lH'nwlf with an upwnnl jet'k, cilusing her
wrist to hit Marilmth'n jaw. In turn, plaintil'f then hit
Defendant, causing bruising on various parts of Dofendant's body.
lifter Plaint! fl took Maribl,th Hamsey to t1H' hospital for an
examination of her jaw, of which no dal1\iltje WilS found, Defendant
called the police herself. She had to lift her shirt to l"evenl
her injuries to the responding officers and Detective Johnson
stated thnt if Mr. Ramsey returned while he was there, Mr. Ramsey
would be arrested. Charges were pressed against both Defendnnt
and Pia inti f f, although the charges aga inst Mr. Ramsey were
subsequently dropped ny Defendant.
6. Denied
1995, Plaintiff
Teaberry Drive,
Pennsylvania.
further abuse.
as stated. It is admitted that on October 16,
and Maribeth Ramsey left the residence at 35
Carlisle, Middlesex Township, Cumberland county,
It is denied that such actions were to avoid
7. The allegations of Paragraph 7 are a conclusion of law
to which no response is required. To the extent it may be deemed
factual, it is hereby denied that Plaintiff and his children will
be in immediate and present danger from abuse from Defendant. It
is further denied that Plaintiff and his children are in need of
protection from such abuse.
B. 'l'he a 11egat ions of Paragraph B are a conclusion of law
to which no response is required. To the extent it may be deemed
factual, Defendant is without knowledge as to the desires of
Plaintiff.
9. 'I~e allegations of Paragraph 9 are n conclusion of law
to which no response is required. To the extent it may be deemed
factual, it is denied that Defendant has used or threatened to use
any weapons, and it is further denied that Defendant ever abused
Plaintiff.
D. TEMPORARY CUSTODY
10. Admitted.
4. on various dates, Plaintiff/counter-defendant has
participated in inappropriate behaviors such as throwing things,
slamming doora, and even broaking a hole in the master bedroom
door. Ono of the items which was thrown was the sewing machine
belong ing to Dofendant /counter-plai nti ff, which was dropped on the
floor and broken.
5. On one date, Plaintiff/counter-defendant verbally
harassed Defendant/counter-plaintiff and he recorded her with a
video camera as part of the ongoing verbal harassment.
6. On numerous occasions, Plaintiff/counter-defendant has
been observed by the minor chi Idren of the parties while using
profane language towards and hitting and pushing
Defendant/counter-plaintiff.
7. On March 4, 1995, Plaintiff/counter-defendant and
Defendant/counter-plaintiff were arguing in their bedroom. Mr.
Ramsey was sitting on the bed and Ms. Ramsey reached across him to
get a pair of glasses. plaintiff/counter-defendant jumped up and
immediately struck Defendant/counter-plaintiff in the right eye,
resulting in a bruised, black eye.
8. on August 27, 1995, Defendant/counter-plaintiff was in
the kitchen and Plaintiff/counter-defendant entered the kitchen.
For reasons unknown to Defendant/counter-pia intiff, Mr. Ramsey was
very angry. Ms. Ramsey had a fork in her hand at the time and Mr.
Ramsey asked her loudly, "What are you going to do, stab me with
that fork?" III! then picked up the Defendant/counter-plaintiff and
threw her against the refrigerator, causing her to land on the
floor on her left knee. Ms. Hamsey's knee, left thigh, and the
left side 01 her chin sustain",l bndses and she was forced to seek
aid at the Carl isle Domestic Violence Shelter. Said injudes were
observed at that time by Dr. lIeidi 1,. JOOB, MD., Jessica lIart, MlI,
and a woman named Loin at the Bhelter.
9. In the evening of lIugust 31, 1995, Defendant/counter-
plaintiff and Plaintiff/counter-defendant had an argument. Mr.
Ramsey pushed Ms. Ramsey, causing her to fall backward into her
chair and her arm scraped the corner of the wall. This resulted
in a scrape and a lump on Defendant/counter-plaintiff's arm.
Plaintiff/counter-defendant then twisted Ms. Ramsey's right
forearm and pulled her down until she was on her knees. This
altercation was observed by the minor child, Maribeth Ramsey, who
asked her father to stop. These injuries were observed by Dr.
Heidi L. Joos, MD. and Jessica Hart, MlI.
10. On October 27, 1995, Plaintiff/counter-defendant came to
the marital residence with the intent of taking the minor child,
Catherine Ramsey, by force, after he had filed his Petition for
Protection from lIbuse from Defendant/counter-plaintiff. He
physically assaulted Ms. Ramsey at this time and the police were
called to the scene. Mr. Ramsey also put her in fear of imminent
bodily injury.
WHEREFORE, the Defendant/counter-plaintiff requests that this
Honorable Court enter a Protection From Abuse Order:
A. Excluding Plaintiff/counter-defendant from the marital
residence at 35 Teaberry Drive, carlisle, Cumberland county,
Pennsylvania and from any other residence Defendant/counter-
plaintiff might choose to establish;
B. Directing Plaintiff/counter-defendant to cease and
desist attempts to contact or visit Defendant/counter-plaintiff by
telephone or otherwise, to refnlin from heing in the physical
presence of Defendant/counter-plaintiff pending final hearing and
then for a period of time not to exceed one year;
c.
Directing Plaintiff/counter-defendant to
threatening, harassing or verbally
cease and
abusing
desist
.
Defendant/countor-plaintiff in any manner pending a final hearing
and thon for a period of time not to exceed one year;
D. Direot Plaintiff/counter-defendant
Defendant/counter-plaintiff's counsel fees;
to
pay
E. Direct Plaintiff/counter-defendant to reimburse
Defendant/counter-pia intlff' s taxable costs pursuant to 23 Pa.
C.S. Section 6107 (d);
F. Direct Plaintiff/counter-defendant to pay a reasonable
amount of support for Defendant/counter-plaintiff;
G. After hearing to be held within ten (10) days of the
filing hereof, enter a final protective order continuing the
relief set forth above, all for a period of one year;
H. Directing whatever other relief the Court deems
appropriate.
Respectfully submitted,
~ Jt.1b&9
S ef:o en G.' Held
Dissinger & Dissinger
28 N. 32nd street
camp Hill, PA 17011
(717) 97-2840
Attorney for Defendant
III
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resumption of residence with the Plaintiff shall not invalidate this Ortler. The Defendant
shall seek modilication (change) of this Ortler before resuming residence in the Plaintiffs
domicile. wherever it may be.
Temporary custody of ".- rrni~4 Ihl~~ II.i1d..II. Maribeth Ramsey. age 11; U.....
RamuS". 1St 1-4. 110.:1 Cdll,,,,;,,~ RanuC). a!1 0, is hereby awartled to the Plaintiff, ROBERT
C. RAMSEY.
The Defendant is ordered to refrain from having any contact with the Plaintiff
(including, but not limited to, restraining the Defendant from entering tile place of
employment or business or school of the Plaintiff and from harassing the Plaintiff. Plaintiff's
relatives or minor children.
This Order shall remain in effect until a linal order is entered in this case. A hearing
shall be held on this matter on the ,A,..,( day of '1'Uwml<..M...-. 1995, at
I: 30 f .M. in Courtroom No.L, Cumberland County Courthouse. Carlisle.
Pennsylvania.
The Cumberland County Sheriff s office shall attempt to make service at the
Plaintiffs request, but service may be accomplished under any applicable rule of Civil
Procedure.
The Middlesex. EastPennsboro and Silver Spring Township Police Departments will
be provided with a copy of this Order by attorneys for Plaintiff. This Order shall be
enforced by any law enforcement agency where a violation occurs by arrest for Indirect
criminal contempt without warrant upnn probable cause that this Order has been violated.
whether or not the violation Is committed In the presence of Ihe police officer. In the event
that an arresl is made under this section, the Defendant shall nol be laken 10 jail but shall be
Plaintiff and his childrcn, and by physical menace has placed the Plaintiff and his children in
fear or imminent serious bodily injury. This has included hut is not limited to the following
specitic Instances of abuse:
a. On Octoher 16, 1995, Defendant shovcd and pushed to the ground;'thc
couplc's minor daughter, Mariheth Ramsey, used obscenc language and spit in the minor's
face.
b. On Octoher 15, 1995, Defendant poured ice water on minor, Maribeth
Ramsey, while she was sleeping. The minor left the residence and stayed with a neighbor.
Defendant then used obscene languagc with husband degraded him to the parties's minor
child, Catherine Ramsey. Plaintiff attempted to get away from the Defendant howevcr,
Defendant continued to block Plaintiff's way. Plaintiff wcnt outside in an attempt to again
remove himself from the violent rages of the Defendant and Defendant then thrcw a pair of
golf shoes at Plaintiff. Plaintiff then attempted to ignore Defendant by tending to his rose
garden. Defendant then produced a pair of clippers and began clipping off the roses in a
threatening manner, placing the Defendant in imminent ahuse. Plaintiff retreated to the
family residence when the Dcl'endant followed. Defendant tben hit Plaintiff in the right eye,
punched and kicked at Plaintiff's groin cutoff a piece of Plaintiff's hair with a pair of
scissors, dragged Plaillliff around tbe living room by his hair. Plaintiff then went into the
parties' bedroom IInd locked the door. The Defendant managed to pick the loek of the
bedroom door and cnntinued to hit and kick Plaimiff. Defendant then obtained water from
the parties' bathroom and threw it on Plaintil'!' and left the parties bedroom. Plaillliff then re-
locked the bedroom door IInd barricaded same. Defelllhll1t then hroke the door from the
hinges IInd oUlof the frame. She then began hitting Plaintiff with the door as he lay on the
bed.
c. On September 9, 1995 police were called to the parties' residence. Defendant
had been hitting the Plaintiff. Defendant hit thc minor, Mlltthew Ramsey, causing his mouth
to bleed. The Plaintiff attempted to record the mntings of the Defendant. Thc Defcndant
attempted to obtain the recorder. Plaintiff put the recordcr in his jeans. Defendant then sat
on tile Plaintiff and cut open his jeans in an altemptto obtain the recorder.
d. On Fcbruary 17, 1995 Defendant asused (hc minor child, Marjbcth Ramsey,
by punching her in the face and causing blceding from (he mouth.
e. On January 16, 1995 (he police werc called to the parties residence.
Defendant again struck the minor, Maribeth Ramsey.
6. On O~tober 16, 1995 the Plaintiff and his one child, Maribetll Ramsey left
their residence at 35 Teaberry, Carlisle, Middlcsex Township, Cumberland County,
Pennsylvania in order to avoid further abuse.
7. The Plaintiff believes and therefore avers that he and his children will be in
immediate and present danger of abuse from thc Defendant should he return to the home with
his children without the Defendant's cxclusion and that he and his children are in need of
protcction from sueh abuse.
8. The Plaimlff desires that thc Defendant be restraincd from emcring his place
of cmployment, business or school having IIny contllct wilh him, harassing (hc PllIintiff or
Plaintiff's rclalives, or minor children or Ihc entering the childrcn's schools.
9. The Defendant has uscd or threatened to use thc foilowing weapons in his
abuse of thc Plaintiff (and/or the minor children): Scissors.
12. The Plaintiff has no knowledge of IIny custody proceedings conceming these
children pending before a court in this or any other jurisdiction.
13. The Plaintiff does not know of any pcrson not a party to this action who has
physical custody of the children or claims 10 have custody or visitation rights witli respect to
the children.
14. The best interests and permanent welfare of thc children will be met if custody
is temporarily granted to thc Plaintiff pending a hearing in this matter because:
a. The Plaintiff is a tit parent who can best take care of his children.
b. The Defendant has shown by her abuse of the Plaintiff that she is not an
appropriate role model for the children.
c. The Defendant has demonstrated by her abuse of the children that she is an
unlit parent.
C. EXCLUSIVE POSSESSION
15. The home from which the Plaintiff is asking the Court to exclude the
Defendant is owned in the names of ROBERT C. RAMSEY and MAIULYN S. RAMSEY.
16. The Plaintiff currcntly hlls no place to stllY with his children except the marital
home.
17. The Plaintiff deslrcs possession of thc home so as to give the greatest degree
of continuity to lives or the children lInd III allow them to continue their education at their
schools and to continue thcir sehoolllnd socilllllctivilles.
WHEREFORE, pursuant to the provisions of the "Protcction from Abuse Act" of
October 7,1976,23 Pa.C.S.A. Section fJlOl ~ :i\lli., ;IS mnendcd, the Plaintiff prays this
Honorable Court to grant the following relief:
A. Gram a Temporary Order pursuant to thc "Protection from Abuse Act:"
I. Requiring tile Defendant III refrain from IIbusing tllC Plaintiff and his minor
children or placing thcm in fear of abuse.
2. Requiring the Defendant to refrain from having any contacl witll the
Plaintiff, including, but not limited to, restraining the Defendant from entering the plaee of
employment or busincss or school of the Plaimiff and from IJ;lrassing the Plaintiff, Plaintiff's
relatives or minor children.
3. Granting temporary custody of thc minor children to the Plaintiff;
4. Granting possession of the home located at 35 Teaberry Drivc, Carlisle,
Middlesex Township, Cumbcrland County, Pcnnsylvania to the Plaintiff to the cxclusion of
the Defendant pending a linal ordcr in this matter;
5. Ordering the Defendant to stay away from the residence located at 35
Teaberry Drive, Carlisle, Middlesex Township, Cumbcrland County, Pennsylvania.
6. Ordering thc Defendant 10 stay aW;ly from any residence thc Plaintiff may
in the future establish for himself; and
n. Schedulc a hcaring in accordancc with the provisions of thc "Protection from
Abuse Act," ;lnd, atier such he;lring, enter ;In llI'dcr to he in cffect for a pcriod of onc year:
I. Hequiring the Dcfend;lnt to rcfrain from ;lbusing the Plaintiff or his minor
ehildren or pl;lcing them In fe;lr of abuse.
2. Requiring the Defendmll to refrnin from having any contact with thc
Pllllntiff, Including, but not limited 10, restraining the Dcfendant from cntering the pl;lce of
employmcntor business or schnnl nf the Plaintiff and from harassing the Plaintiff. Plaintiff's
relatives nr minor children.
3. Granting pnssession of thc residcnce at 35 Teaberry Drivc, Carlisle,
Middlesex Township, Cumbcrland County, Pcnnsylvllnia, to the Plaintiff tn thc exclusion of
tile Defendant.
4. Ordering the Defcndant to stay away from the rcsidence located at 35
Teaberry Drive, Carlislc, Middlescx Township, Cumbcrland County, Pennsylvania.
5. Ordering thc Defcndant to stay away from any rcsidcnce the Plaintiff may
in the future establish for himsc1 f.
TIle Plaintiff further asks that this a copy of tllis Petition and Order be dclivered to
the Mlddlescx Township, East Pcnnsboro Township and Silver Spring Township, police
Departments as thc police Departmcnts with jurisdiction to cnfnrcc this Ordcr.
The Plaintiff prays for such other rclief as may be just and proper.
COUNT 11
CUSTODY UNDER PENNSYLV ANlA CUSTODY LAW
I. Thc 1I11cgutlons of Count I abovc arc incorporatcd hcreln as If fully set linth.
2. The best intcrests unu permancnt welfure of thc children will be scrved by
confimllng custouy in the Plaintiff as set forth in Puragruph 14 of the Petition.
WlIEREFOHE, pursuant to 23 P.S. Scctlon 1001 ~ I!lal., IInd other applicable rules
IInd IIIW, the Plaintiff prays this \1onnl'Ublc Court to awuru custody of the mlnnr chlldrcn to
him.
resumption of residence with the 1'IIIInl1l1 shllllnul Invlllhlllle lhis lIlIll'L The Defcllllllnl
shall seck moditiclltiun (chllnl!c) III' lhls Older helorc rcsumlulllchhlenl'e lnlhe 1'IIIInllll 'h
domicile, whercver il mllY be.
Temporary custody III' [.
..
....
Mllriheth Itllmhcy, IIlle 17;, r
-it
....
I r 1 . ..
.": hClch)' 11\\'IIIlICIIIUlhe 1'11I1nllll, IU)JIEln
C. RAMSEY.
Thc Ilefendllnt is lII'dered Iu rdrain Inlln IlIlI'inlllln)' ,'lInlllll \\'lIh Ihc 1'IIIInl1l1
(including, bUI not IImitcd Ill, rCMrllinirllllhe Ilefelldlllll IIUIII elllerilllllhe plllce III'
employment IIr busillcss or school of thc PllIilltillllllll 1111111 hlllllhsllllllhe I'llIintll1, 1'11Ilntiff's
relatives or minor children.
This Order shllll rell1l1ill In ellcclulllilll firllllulller lh cntcrcd inlhlh CllSC. A hearin!!
shall be held IInthis millieI' IInthe ;"nJ dllY uf NO Vl,/JJbuC.., II)II~, III
~.M. ill Courtl'llulI1 NIL,d., ('lIl11belllllld l'lIulIly l'lIullhuUhC, ('lIrlisle,
I'enllsylvanlll.
The Cumhcrland ('ounty Sherill\ IIl1ke Sllltllllllell111t hi II1l1kc service ul the
I'laintiff's requcsl, but service mil)' hc allulI1pllhhellunder uny upplicuhle nile of Civil
I'roeedurc.
Thc Middlesex, Eusl I'ennhblllu IInll Silvcl Spl Jnll TlI\\'nhhlp I'lIlice Ilepurtments will
he provided with u cIIPy uf this Older h)' 1I1l0IlW)'h lor I'llIllllill. This Order shull he
enfilrced hy uny hlw cnhllcclI1enl IIl1cIIC)' whele II vlullIllllnllcclII's by IUTcst hlr indircct
crhllinlll conlell1pt WilhllUl Willi lint UPUlllllubllble "III1hC thllllhls Older hilS heen villluted,
whether 01' nut Ihe viulullun ih cUll1l11llled illlhe plehelllc ullhe pulice IIfficer. In the event
Ihlll anllrresl is II1l1de undcr thih M~lllun, lhe Ilclellllllnl hhllllnul he tukenlll juil but shall be
ROBERT C, RAMSEY,
Plaintiff
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
for himself and on behalf
of his minor children
CIVIL ACTION - LAW
vs.
,/',-. L Vl..L
NO. CIVIL 1i9S -r;........
MARILYN S. RAMSEY,
Defendant
PROTECTION FROM ABUSE
AND CUSTODY
PETITION FOR PROTECTIVE ORDER AND CUSTODY
RELIEF UNDER THE PROTECTION FROM ABUSE
ACT, 23 Pa. C.S.A. Section 6101 et. seq,
A. ABUSE
1. TIle Plaintiff is an adult individual whose permanent address is 35 Teaberry,
Carlisle, Middlesex Township, Cumberland County, Pennsylvania 17013. The Plaintiff
brings this action for himself and the parties three minor children.
2. The Plaintiff is lemporarily staying at an undisclosed location for his own
protection and to avoid further abuse as is more fully set forth herein, This address will be
furnished to Ihe court upon requcst.
3. The Defendant is anudult Individual residing at 35 Teaberry Drive, Carlisle,
Middlesex Township, Cumberland County, Pennsylvania, 17013.
4. The Defendant Is the spouse of the Plalllliff.
5. Sincc curly 1990, the Defcndant has uttempted to cause and has intentionally,
knowingly. or recklessly caused hodlly InJury, physicully abused the minor children and Ihe
Plaintiff and his children, and by physical menace has plllced the Plaintiff and his children in
fear or immincnt scrious bodily injury. This has includcd but is 110t limited to the following
specific instances of abuse:
a. On Octobcr 16, 1995, Defendant shoved and pushed to Ihe ground, the
couple's minor daughter, Maribeth Ramsey, used obscene IlInguage and spit in the minor's
face.
b. On October 15, 1995, Defendant poured ice water on minor, Mariheth
Ramsey, while she was sleeping. The minor left the residence and stayed with a neighbor.
Defendant Ihen used obscene language with husband degraded him to the parties's minor
child, Catherine Ramsey. Plaintiff attempted to get away from the Defendant however,
Defendant continued to block Plaintiff's way. Plaintiff went outside in an attempt to again
remove himself from the violent rages of the Defendant and Defendant then threw a pair of
golf shoes at Plaintiff. Plaintiff then attempted to ignore Defendant by tending to his rose
garden. Defendant then produced a pair of clippers and began clipping off the roses In a
threatening manner, placing the Defendant in imminent abuse. Plaintiff retreated to the
family residence when the Defendant followed. Defendantlhen hit Plaintiff in the right eye,
punched and kicked at Plainliff's groin cutoff a piece of Pllllntiff's hair with a pair of
scissors, dragged Plaintiff around the living room by his hair. Plaintiff then went into the
parties' bedroom and locked thc door. Tbe Defendalllmanaged to pick the lock of the
bedroom door and continued to hit and kick Plaintiff. Defendant then obtained water from
the parties' balhromn and thrcw it onl'lalllllff and Icft thc parties bedroom. Plaintiff then re-
locked Ihe bedroom door and barrlcllded same. Dcfendantthcn hroke the door from the
hinges and out of Ihe framc. She then hegan hilling Plaintiff with the door as he lay on the
hcd.
c. On September 9, 1995 police were called to thc parties' residcncc. Dcfellllunt
had been hitting the Plaillliff. Defendunt hit the minor, Matthcw Hamsey, causinll his mouth
to hleed. The Plaintiff allempted to record the I'IIntings of thc Defcndant. The Defendllnt
attempted to obtuin the recorder. Plaintiff pUlthc recorder in his jcans. Defendant then sat
on the Plaintiff und cut open his jeans in un allemptlo obtuinthc recorder.
d. On February 17, 1995 Defendant asused the minor child, Maribeth Ramsey,
by punching her in the face and causing blceding from thc mouth.
e. On January 16, 1995 the police were callcd to the parties residence.
Defendant again struck the minor, Maribeth Hllmscy.
6. On October 16, 1995 Ihe Plaintiff and his one child, Maribeth Ramsey left
their residence at 35 Teaberry, Carlisle, Middlesex Township, Cumberland County,
Pennsylvania in order to avoid further abuse.
7. The Plaintiff believes and therefore avers that he and his children will be in
immediate and present danger of abuse from the Defendant should he return to the home with
his children without the Defendant's exclusion and that he und his children arc in need of
protection from such ubuse.
8. The Plaintiff desires thulthe Dcfendunt bc restruined from entering his place
of employment, business or school hllving uny colllact with him, hllrllssing the Plllintlff or
Plaintiff's rclativcs, or minor children or Ihe entering the children's schools.
9. The Dcfendlllll hilS used or threatened III usc the following wcapons in his
abuse nf the Plaintiff (and/or the minor children): Scissors.
}
12. The Plaintiff has no knowledge of any cuslody proceedings concerning these
children pending before a court in this or any other jurisdiction.
13. 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.
14. The best interests and penllanent welfare of the children will be met if custody
is temporarily granted to the Plaintiff pending a hcaring in this matter because:
a. TIle Plaintiff is a lit parent who can best take care of his children.
b. The Defendant has shown by her abuse of the Plaintiff that she is not an
appropriate role model for the childrcn.
c. The Defendant has demonstrated by her abuse of the children that she is an
unlit parent.
C, EXCLUSIVE POSSESSION
IS. The home from which the Plaintiff is asking the Court to exclude the
Defendant is owned In the names of ROBERT C. RAMSEY and MARILYN S, RAMSEY,
16. 11le Plaintiff currently has no place to slay with his children except the marital
home.
17. The Plaintiff desires possession of the homc so as to give the greatest degree
of continuity to lives of the children and to allow them 10 continuc their education at their
schools and to continue Iheir school and social activities.
WHEREFORE, pursuant 10 the pl'llvisions of the "Protection from Abuse Act" of
October 7,1976,23 Pa.C.S.A. Section 610llj ~., as lImended, the Plaintiff prays this
Honorable Court to grant the following relief:
A. Grant a Tcmporary Order pursuant to the "Protection from Abuse Act:"
I. Requiring the Defendllnt to rcfrain from lIbusing the Plaintiff and his minor
children or placing them in fcar of abuse.
2. Requiring the Defendant to refrain from hllving any contllct with (he
Plaintiff, including, but not limited to, rcstraining the Defendant from entering the plaee of
employment or business or school of the Plaintiff and from harassing the Plaintiff, Plaintiff's
relatives or minor children.
3. Granting temporary eustody of the minor children to the Plaintiff;
4. Granting possession of the home located at 35 Teaberry Drive, Carlisle,
Middlesex Township, Cumberland County, Pennsylvania to the Plaintiff to the exclusion of
the Defendant pending a final order In (his mailer;
5. Ordering the Defendant to stay away from the residence located at 35
Teaberry Drlvc, Carlisle, Middlescx Township, Cumberland County, Pennsylvania.
6. Ordering the Defendllnt to stay away from any residence Ihe Plaintiff may
in the future establish for himsclf; lInd
D. Schedule a hearing in accordancc with the provisions of the "Protection from
Abuse Act," and, after such hcaring, enter an order to be in effect for a period of one year:
I. Requiring the Dcfendanl to refrain from ahuslng the Plaintiff or his minor
chlldrcn or placing them in ICllr of IIbuse.
2. Requiring the Defendant to refrllln from having any contacl with the
PllIintifT, including, but not limited to, restraining Ihe Delcndlllll from entering Ihe plllce of
employment or business or school of the Plaintiff and from harusslng thc Plllintiff, Plllintlft"s
relatives or minor children.
3. Granting possession of the rcsidcnce at 35 Tellberry Drivc, Carlislc,
Middlesex Township, Cumbcrland Coullly, Pennsylvllniu, to thc Plaintiff to the exclusion of
tile Defendant.
4. Ordering the Defendalll to stay uwuy from thc rcsidencc located at 35
Teaberry Drive, Carlisle, Middlesex Township, Cumberland County, Pennsylvania.
5. Ordering the Defendant to stay aWIlY fl'Om any residcnce the Plaintiff may
in the future cstablish for himself.
The Plllintiff further asks that this a copy of this Pelition and Order he delivered to
the Middlesex Township, East Pennsboro Township and Silver Spring Township, Police
Depllrtments as thc Police Depllrtmcms with jurisdiction to enforce this Ortler.
The Plaintiff prays for such other relief as may he just and proper.
COUNT 11
CUSTODY UNDER PENNSYLVANIA CUSTODY LAW
I, The allegations of Count lllbove are incorporated herein as if fully set forth.
2. The best imercsts IInd permunent welfare of the children will be served by
confinning custody in the Plaintiff liS set forth in ParugruJlh 14 of Ihe Petition.
WHEREFORE, pursuant \() 23 P.S. Section 1000ltl fil:ll., and other applicable rules
and law, the Plaintiff prays this Ilonorable Courl 10 IIwllrd custody of thc minor children to
him.
~
ROBERT C. RAMSEY, 1 IN THE COURT OF COMMON PLEAS OF
Petitioner 1 CUMBERLAND COUNTY, PENNSYLVANIA
1
V. 1
1
MARILYN S. RAMSEY, 1 CIVIL ACTION - LAW
Respondent I NO. 95-6062 CIVIL TERM
IN REI CUSTODY
ORDER OF COURT
AND NOW, this 11th day of February, 1998, upon
agreement of the parties, it is ordered and directed as followSl
1. The parties shall have shared legal custody of
their children, Matthew Philip Ramsey [OOB: March 18, 1982] and
catherine Anne Ramsey [DOBI March 24, 1987],
2. Father shall have primary physical custody of said
children subject to partial physical custody of mother as
followSl
a, Every other weekend from Friday at 5:00 p,m.
until sunday at 7100 p,m.
b, Alternating holidays, provided, however,
that mother shall always have the children on Mother's Day and
father shall always have the children on Father's Day.
c, Two non-consecutive weeks over the summer.
Mother shall give father at least thirty days notice of her
intention to exercise such week-long periods of partial custody,
d, At such other times as agreed upon by the
parties.
The above periods of partial custody shall be
~
exeroised so long as mother lives with her parents or a sibling.
If those living arrangements change, the issue of partial
oustody shall be revisited by the court unless the parties
otherwise agree.
3. Both parties will make eure that the children
attend all scheduled medical appointments and take all
prescription medication during the periods the children are in
their individual custody and control.
4. Each party shall faithfully take any and all
medication prescribed for him or her by a treating physician.
5, Neither party shall take any prescription
medication or other controlled substance that has not been
specifically prescribed for his or her use,
6. It appearing that both parties and the children
will be living in Paulding county, Georgia, either party may
petition the courts of said county to enforce or modify this
order.
By the court,
~.H
Edward E. Guido, J,
Lisa M. coyne 1 Esquire
For the Petit oner
- L'~i""'.v f"'(I'u,(,
;)..jlll'TI'
"s.f
Gerald s. Robinson, Esquire
For the Respondent