HomeMy WebLinkAbout95-06112
.
;I
'"
~~c
~.. .~
;~j~O
~t~~-_\:j~-, - -
~~~l~,~
b,"
l~'1
~"".:"" "
4,':L:-."",
$~~::;,~.
--""J'"
~{~. .
-0;:,0'. .
~'~;-';-
n
~
-
.,
.
'U)
cr
.
(.)
'<
LINDA ANN ORRIS,
Plaintill'
IN TIlE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, pENNSYLY ANIA
v,
NO lJ5-Cl112 CIVIL TERM
RonERT J. 1I00YER, JR,
Delcndanl
CUSTODY
CUSTODY ORDER
"t
AND NOW, this ,_to day of Decemher, 191J7. upon consideration ofthc parties' Consent
Allrecmcnl, Ihe followinll Order is entered with regard to cuslody of Ihcir child, Samantha
Joscphinc lIoovcr
L Thc partics shall sharc legal custody of the child
2, The 11l0ther shall have primary physical custody of the child,
), As long as the tat her mainlains sale, clean and slahle housinll to accommodate the
child, he shall have panial cuslody ofthe child on ahel1lating IVt.'ekends li'ol1l Friday al 6:00 1',111, unlil
Sunday at 6:00 pm. one day each week (10 he llIutually allr~'Cd upon by Ihe pal1ies) Irom 5:00 P,IlI.
unlil8:30 pm, and at other tillles llIulually allr~'\.-d upon by Ihe parties,
4, The parties shall ahemale the Ibllowing holidays Irolll noon until 9:00 1'111: New
Yeal's Day, Easler, MelllOlial Day, July 4th, and Lahor Day, The lalher will hegin the holiday schedule
with New Yea~s Day in ll)<)ll
5 Thc partics shall share Ihc Thanksgivinll Day holiday with the lilthcr ha\;ng the child
li'OII14,OO pili untillJ.oO p In
Cl The ClII;stlllas holiday shall he shall-d by the pal1ies on an ahel1lating hasis each year,
onc parent hal;ng thc child on ChriSllllllS Eve IhulI h 00 P 111 until rlllistllllls DllY 81 I 00 pili and the
other parcnt having the child on Clllisllllas Dayal 1.00 pili unlil <)00 pili Ilowevcr, if D~'CClllher
26th lalls 011 a wL'Ckend day in yelll's the tilt her has the child on DL'Cemher 251h, or if he tillS DL'CelllhL'f
261h 011' fnlln work, hc lIIay kl'Cp thc child ovcl1light and rclum hcr to thc mothcr at 100 pm onthc
261h Thc Ihthcr shall havc thc child on ('IlIistllllls Day fimn Il~) p.11I. until9()() pm in 1997.
7. 'f11C fhthcr sludl lulVc 0 lilllr hour pcriod of partial custody wilh thc child on her
birthday each ycar allimcs lIIulUlllly IIgrcl\lupon hy thc panics
8. Thc fhlhcr sholl havc Ihc child on Fathcr's Day fillln I ().(~) 11m unlil (, ()() Pili., Rnd thc
1II0thcr shall havc thc child on MOlhcr's Day If thc child is in thc lathers care, thc child shall bc
translen-oo to (he lIIother's carc at JO(~) a m
9. During his Jlcriods of panial cUSlnuy with thc child thc lathcr shall nOI altcr her
appearancc H& get thc child's hair cuI, havc the child taltocd, or picrcc thc child's car or any other plll1
of her body) withoutlhe wriltcn pcnuission ofthc lIIothcr
10. TIIC lathcr shall providc trnnsportation during his ftcriods ofpartiall'llstody
II, TIlc parties shall nol usc lI!cohol in cxccss during pcriods of partial custody with the
child,
12, Each pany shall cnler into individual counscling with a ccr1ified therapisl to address
issues including, bUI not Iilllited 10, substancc abuse, angcr monagcmelll, and parenting skills, Thc
palties shall follow Ihc recommcndations ofthcir thernpist and rcmain in cuunsclinglhr allcast six (6)
lIIonths or nntil rclcaSl.'lI by their thcl1lpisl. Veriticllliol1 of IIltcndancc lIIay Itc continned through
partics' counsel,
13, The lIIolher and lathcr, by mulual agreclllcnt, lIIay valY filllnlhis schedulc 01 any tillie,
but thc Ordcr shall remain in ellect unlil fiuther Order of Court
14. The partics shllll notify the other llf allmediclll cllrc Ihe child reccivcs whilc in their
carc. Elich parent shllll nolily the othcr immcdiately of medical cmcrgcncies which arise while Ihe child
is in that pllrenl's care,
LINDA ANN ORRIS.
l'laintitf
IN TIlE COURT OF COMMON I'LEAS OF
CUMBERLAND COUNTY. PENNSYLVANIA
v.
NO 'lS-ClI12 rlVIL TERM
1l0HEIlT 1. 1I00VElt. JIt.
Derendant
CUSTODY
CUSTODY AGREEMENT
This Agreement is enlered on this ~_~ day or December, 1997. by Ihe plaintin: Linda Ann
Orris, and the defendant. Robert 1. lIoover. h Tbe plainlil1' is represented by Joan Carey of
LEGAL SERVICES. INC, the defendant is represented by Gail C Calderwood. Certilied Legal
Intern and Thomas M, Place. Allorney at Law. of the Family Law Clinic The parties agree that
the following custody schedule ror their child. Samantha Josephine lIoover, may be entered as a
Custody Order.
a) The parties will share legal custody of the child.
b) The mother will have primary physical cuslody orlhe child,
c) As long liS the tilt her maintains sare. c1eanllnd slable housing 10 accommodale
the child. he \\111 have partial custody ofthe child on alternaling weekends from
Fliday at hOO pm until Sunday lit h.OO pm. one dllY each week (to be
mutually IIgrL't.'1.lupon by the plUlies) limn S 00 pl11 unlil 8JO pm.. and at
other times l11ulUlllly IIgrL'Cd upon by Ihe pllrties
d) The pllrties \\111 IIltemale the lollowil1g holidays Ii'olll 1100n until I):O() p,m.:
New Yeur's DIlY. Ellsler. Memmilll Day. July 4th, IIl1d LlIbor Day, The tiuher
will begin the holidllY schedule with New Yem's Day in 11)98.
e) The parties will share the Thanksgiving Day holiday with the father having the
child from 4:00 p.m, unIi19:00 pm.
f) The Chrislnl8s holiday will be sll8rcd by the parties on an alternating basis each
year. one parent having the child on Christmas Eve HUIll 6:00 p.m. until
ChristJl\8S Day at 1:00 p.m and the luher parcnl having Ihe child on ChrislJl\8S
Day at 1:00 p.m, until 9:00 p.m, Ilowever, if December 261h falls on a
weekend day in years the father has the child on December 25th, or if he has
December 261h on' from work. he may keeJlthe child overnight and return her
to the mOlher al 1:00 p,m. on Ihe 26th, The father will have the child on
Christmas Day from 1:00 p.m. until 9:00 p.m. in 1997,
g) The father will have a lour hour period of partial custody with the child on her
birthday each year at times mutually agreed upon by the parties.
h) The father will have the child on Fathcl's Day from 10:00 am, until 6:00 p.m.,
and the mother will have the child on Mothers Day. If the child is in the
father's care. Ihe child will be lransferrcd to the Illolher's care at 10:00 a,m.
I) During his periods of panial custody wilh Ihe child Ihe falher will nol alter her
appearance <LIl. get the child's hair cut, have Ihe child talloOO. or pierce the
child's car or any other pall of her body) wilhoutlhe wrillen pennission of too
mother.
j) The falher will provide IllInspollation duling his periods of pallial custody,
k) The pallies will not use alcohol in excess during periods of partial custody wilh
the child,
I) Each party II!lrees to enter into individual counseling with a ccrtitled Iherapist
to address issues including. but nut limited 10, substance IIbuse. anger
manallemenl. and pllrenting skills Thc pllnics IIgree 10 tbllow thc
recommendations oflhcir thelllpist and lemain in CIlunselinglhr IItlcasl six (Cl)
monlhs or until released by Ihcir therapist VClilicatiun ur IIl1cndance I1II1Y be
conlil1lled through panics' counsel
m) 111e mother IInd lather. by mutuIIIIIgrl'Cmcnt. mllY vary li'Om this schedule III
any timc. bUllhe ordcr will rcmwn in e11i.'Ct untillilllher Order ufCourt
n) 111c parties agree thai they will notily the olher or all medical Clll'C the child
receives while in their care Each parcnt will nutity thc othcr inllnedialely or
medical cmergencies which arise while the child is in Ihat plll'Cnt's care
0) nle pallies rcalize thllttheir child's wcll being is paramount 10 IIny dilferences
they mi!lht hllve betwl'Cn thl'lnsclves Therethre. thl'Y agree that neither party
will do an}lhing which may estrange the child tTom Ihe ulher parent. or injure
the upiniun or Ihe child as 10 the olhcr parenl 01 which may hamper the free
IInd nalul'lll developmcnt ofthe child's luve or respcctlhr Ihe other pllrent.
WI JEREI'ORE. the panics rl'ljuestlllllt a Custody Oldcl be enten.'Illo rellecllhe llbove tenns
LLJ. /) ) I' I
LL:;t,/d.ia.. u.. (L I . ( I. ALl, d >' h"' ( I ~ '--
liI\da A Ollis. Plaintilf Ilohcll J I loovel , JI . l>c1cnllllnt
"
I ,', / .
(, "
I , I . ,; ..'1 /. -'
. '14nllh~'
Thomas 1 1'llIcc. Allomey IItl.OW
t'AMU,V '.J\W (",IN\(:
4~ NOIlh Pill S\tl'Ct
Callisle, PA 170Ll
IHiAI, st:RVICt:S. INC.
K Irvinc Row
Cllllisle, "^ 17013
buttocks and back. These marks remained visible for al lcasl Iwenly (20) mlnules. The child
told pelltioner thai respondent had hurt her knee. Respondenl was under Ihe inOuence of alcohol
althe lime of the Inclden!. The New Cumberland police arrived and were unable to control the
respondent. The respondent was removed from Ihe home by the police.
b. On November 8, 1997, at 1:30 a.I11,. Ihe respondenl. upon finding the child asleep
In the parenl's bcd, screamed obscenities althe minor child, causing the child 10 become upse!.
c. On Seplember 27, 1997, petllioner observed the respondent screaming obscenities at
the minor child causing the child to shake and cry.
6, Following Ihe incident on November 18, 1997, pelilioner removed Ihe child
from the home the parties were sharing and look the child to his mOlher's residencc in
L1nglestown, Dauphin Counly, PA 17112. The child has resided with pelitioner in his mother's
house since November 18, 1997.
7. Respondenl has a severe alcohol dependency, consuming alcohol on a daily
basis and in the presence of Ihe minor child.
8. Because of her alcohol dependency, respondent Is unable to properly care for
the child.
WHEREFORE, petilioner requests modification of the current custody order awarding
him primary custody of the minor child pending a conciliation in this matter.
COUNT II
SPECIAl. REUEF
Pelllioner, pursuanllo Pa.R.C,P. 1915.13, seeks an order granting him primary
custody of the Samantha J. Hoover, born 417193, pending a conciliation In this matter.
9. The child was born out of wedlock.
10. The child is presently In the custody of the petitioner who is presently residing
with his mother In 2323 Robin Road, Llnglestown, Dauphin County.
11. Since her birth, Ihe child has resided st the following addresses and with the
following people:
PerIODS
Adlir'eMes
DaleI
Robert Hoover and
Linda Orris
Colonial Park,
Harrisburg, PA
417193-94
Linda Orris
Pat Orris and
Stepgrandfather
New Cumberland, PA
94 - 9S
Robert Hoover and
Linda Orris
322A Reno Street 9S - Sept., 1996
New Cumberland, PA
Linda Orris
322A Reno Street Sept., -
New Cumberland, PA March, 1997
Robert Hoover and
Linda Orris
322A Reno Street March, 1997 -
New Cumberland, PA November 18, 1997
Robert Hoover and
Barbara Layton
2323 Robin Road
Dauphin County
November 18, 1997 -
Present ,
12. The relationship of the petitioner to the child Is that of father. He is single. He
currently resides with the following persons:
Name
}telatlonshlD
Barbara Layton
Harry Layton
Petitioner's mother
Petitioner's stepfather
. ,
. .
13. Pethloner has partlclpaled liS a party In olher Ihlgallon concerning Ihe custody of
the child In this Court. This Court enlered an order In Ihis mailer on December 5, 1995,
granting respondent primary physical custody and pelllioner partial custody of Samantha J.
Hoover.
14. Pelllloner has no Informallon of a cusllxly proceeding concerning the child
pending another court of this Commonweallh.
IS. Pethloner does not know of a person nol a party 10 Ihe proceedings who has
physical custody of the child or claims to have cuslody or visillllion rights whh respect 10 the
child.
16. The besl interest and permanent welfare of Ihe child will be served by granting
the relief requested because:
a) The pethioner is a reponsible parent who can best take care of the minor child.
b) The respondenl has shown by her abusive conductloward the child and her
alcohol dependency that she is unable to care for Ihe child.
17. Each parent whose parenlal r1ghls 10 Ihe child have not been lerminated and the
person who has physical custody of Ihe child have been named as parties to Ihls action,
LINDA A. ORRIS,
plaintiff
for herself and on behalf of
her minor child,
SAMANTHA J. HOOVER,
v.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 95-6112 CIVIL TERM
PROTECTION FROM ABUSE
ROBERT J. HOOVER, JR.,
Defendant
1 If CUSTODY ORDER
AND NOW, this ; day of December, 1995, upon consideration
of the parties' Consent Agreement, the following Order is entered
with regard to custody of the parties' child, Samantha J. Hoover.
1. The plaintiff, hereinafter referred to as the mother,
shall have primary physical and legal custody of the child.
2. The defendant, hereinafter referred to as the father,
shall have partial custody of the child as follows: for a period of
four weeks after the entry of the protection Order and for a longer
period if the father does not obtain housing to accommodate the
child by the end of that period, the father shall have partial
custody of the child sunday from 2:00 p.m. until 6:00 p.m. and each
Tuesday from 5:30 p.m until 8:30 p.m.
3. After the initial four-week period, if the father
establishes safe, clean and stable housing for himself which can
also accommodate the child for overnight periods, the father may
begin a schedule of partial custody on alternating weekends from
Friday at 6:00 p.m. until sunday at 6:00 p.m., and at any other
times mutually agreed upon by the parties.
4. The parties shall alternate the following holidays from
noon until 9:00 p.m.: New Year's Day, Easter, Memorial Day, July
.
.
r:-'
(L)
4th, and Labor Day.
The father shall begin the holiday schedule
with New Year's Day in 1996.
5. The parties shall share the Thanksgiving Day holiday with
the father having the child from 4:00 p.m. until 9:00 p.m.
6. The Christmas holiday shall be shared by the parties on
an alternating basis each year, one parent having the child on
Christmas Eve from 6:00 p.m. until Christmas Day at 1:00 p.m. and
the other parent having the child on Christmas Day at 1:00 p.m.
until 9:00 p.m. However, if December 26th falls on a weekend day
in years the father has the child on December 25th, or if he has
December 26th off from work, he may keep the child overnight and
return her to the mother at 1:00 p.m. on the 26th. The father
shall have the child on Christmas Day from 1:00 p.m. until 9:00
p.lII. in 1995.
7. The father shall have a four hour period of partial
custody with the child on the Child's birthday each year at times
mutually agreed upon by the parties.
8. The father shall have the child on Father's Day from
10:00 a.m. until 6:00 p.m., and the mother shall have the child on
Mother's Day.
If the child is in the father's care, the child
shall be transferred to the mother's care at 10:00 a.m.
9. During his periods of partial custody with the child the
father shall not alter her appearance (~. get the child's hair
cut, have the child tattooed, or pierce the Child's ear or any
other part of her body) without the written permission of the
mother.
C"
lOt The father shall provide transportation during his
periods of partial custody.
11. The father shall not Use drugs and/or alcohol prior to or
during periods of partial custody with the child.
12. The mother and father, by mutual agreement, may vary from
this schedule at any time, but the order shall remain in effect
until either party petitions to have it changed.
13. The father shall notify the mother of all medical care
the child receives while in his care. Each parent shall notify the
other immediately of medical emergencies which arise while the
child is in that parent's care.
14. Neither party shall do anything which may estrange the
child from the other parent, or injure the opinion of the child as
to the other parent or which may hamper the free and natural
development of the child's love or respect for the other parent.
By the Court,
1 \, - \ \-
~! Ll _, I ..
Harold E. Sheely,
. ')l\.( ~
Presid t Judge
Joan Carey
/ LEGAL SERVICES, INC.
,". Attorney for Plaintiff
Robert J. Hoover, Jr.
Defendant
... UI (:
t.:; to:
'J;
I... ..
~In f-o-'
,- ~t: ,-
r-:... ~
11,- - -.; l
r
,.
, It}
\,
,L C'-
, . .
ti..' . j'
F- ~. '-
'.1.. r- G
CJ U'
LINDA ANN ORRIS.
PlaintitT
IN TIlE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY. PENNSYLVANIA
v,
NO. 95,(1112 CIVIL TERM
ROBERT J. 1I00VER. JR.
Delendant
PROTECTION FROM ABUSE
TEMPORARV PROTECTION ORDER
AND NOW.this-11-tJ)day of November, 1997, upon presentation and consideration of
the within Petition, and upon Iindingthat the plaintil1: Linda Ann Orris, now residing at 322A
Reno Avenue. New Cumberland, Cumberland County, Pennsylvania, is in immediate and present
danger of abuse from the delendanl, Robert J lIoover, Jr, the lallowing Temporary Order is
entered.
The defendnnt, Robert J, Hoover, Jr, (SSN 17J-56-2899)(DOR: 5/26/(6), is an ndult
individunl residing at 2223 Robin Road, Linglestown, Dauphin Counly, Pennsylvania, is hereby
enjoined from physically abusing the plaintiff. Linda Ann Orris, or front placing her in fear of
abuse,
The defendant is ordered to stay away from the plaintil1's residence located at 322A Reno
Avenue, New Cumberland, Cumberlnnd County, Pennsylvania, a residence which is leased by the
plaintiff, and is ordered 10 stay away from nny residence Ihe plaintitT may in the future establish
for herself
The defendant is ordered to retrain Irom having any dirLoct or indirect contact with the
plaintiff including, but not limited to, telephone and wrillen communications, except for the
IimitL'll purpose offacililating custody arrangements.
The defendnn\ is enjoined liom hnlAssingllnd slalkinglhe plllintil1' and Ii'om harassing her
relatives, or the parties' minor child
Thc defcndant is enjoined from cnteJin!l thc plaint ill's place of cmploymenl or the day care
facilily ofthe partics' millor child
The delendant is enjoined Ihun removing, damaging, destroying or sellinll any property
owned by the plaintil1'
^ \'Iolallon of tllll Ordu ilia)' subj<<1 IlIr drfrndllnl to: I) ar~lt undrr 23 "a.CS.
16113; ilIa IlrlVllr criminal cODllllalulundrr 23 pa.eS.16\13.1; ii1) a cllargr of Indlrrrl
crlmln.1 conlrDlplundrr 2J "a.CS. 16\14. punlshablr by IlIIprllonmrnlulllo Sl1l1ll0nlhl
and. nnr ofSIOO.OO-SI.OOO,OO; and Iv) civil conlrDllllundrr 23 Pa.es.1611".I,
This Order shall rcmain in ellect until modi lied or tenninated by the Court and can be
eKtended beyond its original expiration date ifthc Court finds that the defendant has committed an
act of abuse or has engaged in a pattelll or practice that indicates risk of harm to the plaintilr
TemporalY custody of Samantha Josephine Hoover, is heleby awarded to the plaintiff,
Linda Ann Orris.
171!! dl!.f!!IIJalll 1,1' on/!!/'t'd 10 I'!!/111'11 III.. l'al'II!!,I' dllld 10 III.. 1'1/.1101(1' /!f III.. IJlalllliff. 77"1
"'""'iff,\ / >t'/k'I'lm!!1I1 .IIIa/ll/.III,IIIIr"I'/alllliff 11I1'l'1I'1l'l'IIIK IIII' dllld.
A III<:ARING SIIALL nt: III~\.I} ON TillS MATn:R ON Tilt: 'f -uj DA \' OF
\)[C:[MBER, 1997. AT 10; 0 (1 .tl.M,.IN COllRTROOM NO. L. (}I. TilE
ClIMHt:RI,AN\) COLI NT\' COlIIHIIOlISE. CAllUSU:. l't:NNS\'LV ANIA.
The plaintilr may plllceed without ple-paymcnt of tees pending a thIther urder aller the
healing
Thc Cumberland County Sherill's Department shall allelllpl 10 make service at the
plaint ill's request and wilhout pre-payment of fees, but service nmy be accol11plished under any
applicable IlJle olTivil Pmccdul c
LINDA ANN ORRIS.
Plaintill'
IN TilE COURT OF COMMON PLEAS OF
CUMOml.AND COUNTY, PENNSYLVANIA
v,
NO 9~.bI12 CIVil. TERM
ROBERT J HOOVER, JR,
Delendant
PROTECTION FROM ABUSE
NOTICE
You have been sued in court If you wish to defend against thc claims set forth in the
following pages, you must take action promptly ancr this Petition, Order and Notice arc served,
by appcaring personally or by attorney at the hearing scheduled by the Court and presenting to the
Court your defenses or objections to the claims sel forth against you, You are warned that if you
fail to do so the Court may procced withoul you, and a judgment may be entered against you by
the Court without further notice for uny money c1aimcd in the Petition or for any other claim or
relief requested by the plainlill', You may lose money or JlIllpel1y or other rights important to
you.
1'1,:.:5 ANI) COSTS
If the case goes to hearing and the judge grants a Protection Ordcr, II surchargc 01'$25,00
will bc IIssessed IIllainst you. You may also hc required to pay uJlto $25000 to reimhurse one of
I.egal Services, Inc,'s funding sources for I.eglll Services, Inc.'s representation of the plaintiff,
'V ou should take thIs I,aper 10 your lawyer al onee, If you do nol have a lawyer or
ea"nol atTord one, go 10 or telel,hone the office set forth below to find oul whel'e you can
get legal help.
COURT ADMINISTRATOR, 4th FLOOR
CUMBERLAND COUNTY COlJRTIIOUSE
CARI.ISI.E,IIENNSYI.VANIA 17013
TELEPIIONE NUM13ER: (717) 24().Cl200
~MERI(:ANS W...." mSAIIIUTI.:S An m' 1990
The Court of COllllllollPleas of Cumherlnnd County is required by Inw 10 comply wilh the
Americans wilh Disabilities Act of 1990 For intimlllltiol1 ahout IIccessihle facilities and
reasonable IIcconllllodalions IIvllilable to disabled individuals having business before the coul1,
please contact our ollice All arrangemenls musl be made lit least 72 hours prior to any hearing
or business belore the COUl1.
a) On or about November 18, 1997, Ihe dclcndanl yellL-d, "I'mgoinl! to kill you,
you fucking bilch ", and when the plainlill'lIied to call 911 Itlr help, he l!rabbcd the
telcphune thlln her IUlI1d, slmck hcr on the hClld wilh ii, pushed hcr down ontothc lovc
seal, pinncd hcr down, stmek hcr inlhe head with thc tclephonc again, chokcd her, and
a!!8in threatcned to kill hcr When Ihc plaintill' called 911 again, thc dclt.'ndant pushed
her 10 thc Hoor, lockl-d his Icgs llround hcr head llnd nl'Ck. and Sljucc7.cd so til!htly that
she could hardly speak The New Cllmherlal1ll Policc were dispatched to the rcsidence
and called an ambulancc lor thc plailltill: \\ho was transp0l1ed to Hanisburl! Hospital
lor trcalml'llt of injlllies shc Il.'cdved as a result of this incident. 'Ille plaintiff also
SllUght medicnl attention from her family doctor the following day for additional
treatmenl ofthcsc injuries
b) In or about latc AUl!ust and mid-Scplember, 1997, thc defcndanl pushed the
plaintUr down onto thc bed and couch, leaned over her in a Ihreatening manner,
pointed his linger in her face whilc yelling at her, and daring her 10 call Q t I,
c) Since approximalely August, 1997, the dclcndant has abused and intimidated
thc phlintin'in ways including, but not limited to, pushinl! her, yelling and pointinl! his
Ilnl!er in hcr lacc whilc standing over her or directly in Ilunt of her, drawinl! back his
list in a threatening manner as if to Ilunch her In addition, on many occasions the
delendanl has scared the parties' child by sneaking up behind her or jumping out at her
and yelling causing the child 10 bl'Collle tiightened, scream, and cl)',
d) TIle plaintitT filed a Petition for I'rulection Onl~'1 Ihr h~'1lielf and on behalf of
the par1les' dauglner, Samanlha, to the above caplion~od number, and a TemllOral)'
11rotection Order was tiled on October 24, 11)1)5 (see IIttoclll'd Exhihit II, inw'lllll8ted
hy ret'erencc) On Deccmber 5, 1')<)5, by aglccmcnt ot'thc panics, l'llltcction and
Cuslndy Orders were ent\.'1ed (see attached Exhibit C' and D respectively, incOllllllUted
by reference)
5, TIle plaintin'belicvcs and therefore avers Ihal she is in inllllediotc ond prcscnt danger of
abuse from the defendant and that she is in need of protectionlrom such ahuse
6 The: plRintilr desire:s IhRt Ihe: delcndonl he prohibit~~llhl1n hllvinllllny direct or indinx.1
contact with the plaintitT including, but not limited to, telephone and written communications, except
for the limited pU'llOse offRcilitatinll custody Dn'lIngem~'111s
7, The plainlilr d\.'Sin.'S that thc delt'lldant be enjoined limn harassing and stalking Ihe
plaintin: and from harassing her relatives and lhe minor child
8. The plaintiff desircs thol the delcndonl hc restraincd Ihull entcring her place of
employmcnl or thc day care litcility of the pal1ies' child
9, The plaintifr dcsires that the defendant he enjoined fhull removing, danl8!!ing,
destroying or selling any propeny own\.-d by the plaintin~
B, t:XCl.IJSIVt: roSSt:SSION
10, The residcnce at 322A Ilcno Avcnuc, Nell' Cumberland, C'umberiond County,
Pennsylvania. from which the plaintitT is IIskingthe Coul1 toonler the defcndllnt 10 slay away lium is
entoo in the name of the plaintill: Linda Ann Oms The delendant is currently rcsiding with his mother
&011 Add.- DIla
PlaintilT and defendant 322A Rello Avenue August of 1995
New Cumberland, PA 10 October 12, 1995
Plaintiff. defendant, 1302 I'ine Street August of 1994
plaintiffs mother, Patricia Onis New Cumberland, PA to August of 1995
her boyfriend, Paul Uouck
Plaintifl' and defcndant Marshall Dlive May of 1994
Camp Bill, PA 10 August of 1994
Plaintifl: her father and 2115 South Front Street January of 1994
step-mother, Donald and Mary Orris Stl'Clton, PA to May of 1994
Plaintiff. defendant, 3rd Street October of 1993
defendant's sister, Carol Steelton,l'A to January of 1994
Dibitteto, and hL'r son, l>crrick
PlaintilT and defendant 5039 Trent Road April 7. 1993
lIanisburg, P A to October of 1993
The plaintiff. the mother of thc child, is Linda A Onis, rcsides at 322A Rcno Avcnue, New
Cumberland, Cumberland County, Pennsylvania
Shc is single.
The plaintitl'l'Urrl'lltly resides alone
The defendant, the lather of thc child, 1l0bel1 J lIoover, Jr. currently resides at 2223 Robin
Road, Unglestown, Dauphin County, Pennsylvania.
lie is single,
The delendant currently resides with thc lilllowing persons
~
Samantha Josephine Hoover
BalbarR and !taITY I.ayton
Richard I.oper
Rdltlonlhlo
his dauglller
his lIIother and stell-fathl'f"
his uncle
14, TIle plaintifffiled for "lIstody of the child thmogh the previous Pmtection Fmm Abuse
action and a Custody Order was cnter,,'Il on [)loccmber 5, 1995, (see allached Exhibit D, incorportated
by reference) which remained in elTect fin the ICl1n oflhc Protection Ordcr.
15, The plaintil1. has no knowledgc of any custody procccdings conccming this child
pending belore a court in this or any other jurisdiction
16, The plaintiff docs not know of any pcrsonnot a pany to this action who has physical
custody of the child or claims to have custody or visitation rights with respect to the child.
17, The b"'5t interests and pennanent welfare of the millOl child will be met if custody is
temporarily granted to the plaintiff pending a hearing in this matter tor reasons including:
a) The plaintiff has provided for the cmotional and physical needs of the
child sincc her birth and is a responsible parent who can best take care of the
minor child,
b) Thc defendant has shown hy his abuse of the plaintiff that he is nol an
appropriate role model for the minor child
c) The defendant's actions havc had an adverse effect on the child,
WHEREFORE, pursuant to thc provisions of the "Protcction from Abuse Act" of October
7, 1976,23 P,S, ~6101 el ~"'!I, as amended, the 11Iaintill' prays this 1I0norable Court 10 grant the
following relief:
A, (ir.nlll TrmporllrY Ordrr punulIlII 10 IlIr "Prolrcllon !'rom Abuse
Act:"
I, Ordering thc delcndantto reliain Ihllll abusing thc plaintilT or Ii'om
placing her in fear or abusc
2, Ordelingthc dclcndanttu lelillin thllll hllving IInY dhecI or indirecl
contact with the plainlill' includiog. but not limited Iu, tclcphone and
wrillen communiclltions, cxccpt lill' thc limited purposc of tucilitating
custody arrangemcnts
3. Ordering thc dcrcndant to rcfi'ain Iimll harassing and slalkinllthe
plaintin. and 1i-0I1I harassing her relntives and the minor child
4, Prohibiting the delendant Ii-um cntcring the plaintif1's place of
employmentllnd thc day cale lucility of the minor child.
S, I'rnhibitingthc dcfendant 1i-1lI11 removing, damaging, dcstrnyinllor
selling propeny owned by the plaintil1'
6, Ordcring the delendant 10 stay aWIlY 1i-llIn the plaintil1's residencc
locatcd at 322A Rcno Avcnue, New Cumbcrland, Cumbcrland County,
Pennsylvania. and Iftllll any rcsidcnce thc plnintill' mllY in the future
establish for herselr
7, Grantingtcmpornl)' custody uf thc minor child, Samantha Josephine
Hoover, to the plaintitl'
D. Schrdulr a hrarlng In Rccordancl' wilh thr provisions of thr
"Protl'etlon from Ahusc Arl," and, artcr snrh hcarlnl!, cnter an ordrr 10 hl'
In l'ITrel for a prrlod of one Yl'Rr:
I, Ordcring thc dclendanttu rcli'ain fi'om abusing thc plaintifl' or fi'OIl1
placing her in leal or abusc
2, Ordcringthc dclendantto rcfi'lIin Ihlmllll\'ingllny dircct or indirect
contact wilh the plaintilf including, but not limited to, telephone and
wrillen comnnmicalions, escept lilf the limited pU'l'ose of Iilcilitating
custody arrangemenls
3, Ordering the delendant to reli'ain Ii'om harassing and stalking the
plaintiO-and Iillln hlllUssing her lehl1ives and the minor child
4, Prohibiting the delendllnt thllll entering the plaintiO's place Ill'
employment and the day care facility of the minor child
5, Prohibitingtbe delendant IhulI removing, damaging, destroying or
selling propeny owned by the plaintifl'
6. Ordering tbe defendant to stay away from the plaintin's residence
located lit 322A Reno Avenue, New Cumberland, Cumberland County,
Pennsylvania, and orderinglhe defendant 10 stay away thlln any residence
the plaintil1-may in the tiJlure establish Ihr herself
7, Ordering the defendant to reimburse the plaintilT's out-of-pocket
losses sutferL'lI os a result oflhe incident on or about November 18, 1997,
inclllding, blltnot limited to, the losses listed on tbe all ached sbeet marked
Exhibit A
8. Ordering the delcndantto pay $250 00 to Cumberland County, one
of I.egal Services, Inc 's Ihnding sources as rcimbursemenl ti,r the cost of
litigating this Cllse, IInd IIssessing the $2500 surcbarge IInd court costs to
the delendanl if Ihe case goes to hellring
9, Granting temporary custody of the parties' child, Samantha
Josephine Iloover, to the plainlilf
"'"
r-.
LINDA A, ORRIS,
IN mE COURT OF COMMON PLEAS OF
Plaintiff
for herse 1 f And on behal f of her
minor child, SAMAN111A J, HOOVER,
v,
CUMBERLAND collNTY, PENNSY1.VANIA
NO. 9~-
CIVil. TERM
ROBERT J, HOOVER, JR, I
Defendnnt
PROTECTION FROM ABUSE
NOTICE
You have been sued in court. If you wish to defe",1 agAinst the claims set
forth in the following pages, you must take nct ion promptly after this Pet I t lon,
order and Notice arc served, by appearing personallY or by attorney at the
hearing scheduled by the Court and present Ing to the Court your defenses or
objections to the clnlms set forth ngninst you, You Are warned that if you fall
to do so the C..ourt mny proceed without you, and n judgment mny be entered ngalnst
you by the Court without further notice for nny money c1nlmed In the Petition or
for any other claim or relief requested hy the plnint I rr. You mny lose money or
property or other rights Important to you,
FF.F~'l AND COSTI!
If the case goes to hearing nnd the judge
surcharge of $25.00 will he nssessed ngninst you,
PIlY attorney fees to Leglll Services, Inc, for
plaint Iff.
grnnts a Protection Order, II
You mny 11150 be required to
their representnt Ion of the
You should take this I'llper to your lnwyer /It once. If you do not have a
lawyer or cannot afford one, go to or telephone the office set forth below to
find out where you can get legal help.
COURT ADMINISTRATOR, 4th FLOOR
CUMBERLAND COllNTY COImmOllSE
CARLI IILE, pr'l'lNSYLV AN I A t 70 13
TELEPHONE NUMl3ER: (717) 240-6200
AMlllllC.ANS WITII IHSAllIt.lTIES ACT OF 1990
The C'..ourtof Common Plens of rumherlnlll\ rounty is required by Inw to comply
wllh the Amerlcnns with nlsnhllitleH Act of 1'l90. For Informntlon nbout
accessible fAcl lit les nnd rellsonllble nccommm!lltlons IIvlIllllble to disabled
Indlvldunlll hnving husinclls heforc the court, plellRe contnct our office, All
nrrnngements must hc mndc lit lenst 72 hours prior to nny hellrlnl! or business
before the court,
'"
~
8) On or about October 16, 1995, thc defendant tclcphoncd thc
plaintiff and threatcncd that he would "get" ber and that shc would
"pay" cnusinll her to fcnr for her sufety.
b) On or about October 12, 1995, the defendant grabbed the
plslntlff's cur keys, twisted the keys her fingers which were
cntwlned in the key ring, and bent her thumb beck causing the
plnlnt Iff pain. The plaintiff left her residence that night for her
own protect ion and to avoid further abuse anr! has not returned, Thc
following day the plaint I ff sought on emergency protcctlon order
from Dietrict Just ice Day (see attached Exhibl t A, Incorporatcd by
rcfcrence) .
c) On or nbout Scptember JO, 1995, the defendant grobhed thc
plaintiff's nrm, tore her shirt, and threw her onto the loveseol.
The dcfendnnt thcn grnbbed the plaintiff's hair and demanded that
she tcll him whcre she had been. The plaintiff sustained a
lacerat ion on her wrist nnd soreness about her arm and bend ns a
reeult of this incident.
d) On or about September 24, 1995, the defendant followed the
plnintlff about the house, put his fist In the plaintiff's face
betwecn her eyes, nnd threatened hcr saying, "I'll knock you out I
I'm ready to punch YOUI You're long overdue" cnuRlnll the plaintiff
to fcnr for her snfety.
c) In or about MIlY of 1995, the defendnnt pushed the plaint Iff
down onto II step clluslng her to strike her neck and bock, As a
result of this incident the plnlntlff hnd Ilmitcd mobility of her
........
~.
neck and soreness nbout her ncck and hack, and she required medical
aUent lon,
f) In or about May of 1994, the defendnnt grahbed the plaintiff
by her hair barret and threw her to the ground.
g) In or about 1993, on scparate occasions the defendant tried to
shove the plainti ff down a flight of approximlltely 17 stairs and
attempted to push the plaintiff's head through n window whl Ie she
held the parties' 3 month-old bahy in her arms,
h) since approximately August of 1993, the defendant has abused
the plaintiff In ways Including, hut not I imlted to, pushing,
shoving, pulling her IlAlr, throwing her about. In addition, the
defendant has violent Iy shaken thc pllrties InfRnt daughter on R
numhcr of occRslons,
5, On or ahout October 12, 1995, the plRinliff and the minor cblld left
their residence Rt 322A Reno Street t Ncw Cumberland, CUmberlRnd County,
Pennsylvanln, In order to avoid further /lbuse,
6. The plaintiff hcl ieves and thcrefore avers that she IInd the minor
child Rre In Immcdlatc nnd prcsent dangcr of IIhuse from the defendRnt should they
rcturn to the home without the defendllnt's exclusion Rnd that they are In need
of prntect Ion from such Rbuse.
7. The plaintiff dcslres that the defendllnt bc prohibited from hnvlng
Rny direct or indirect contact with the pllllntlff InclUding, hut not limited to,
telepbone IIml written communicRtfons.
8. The plaintiff desires thllt the ,lefendRnt he enjolncd from hRrBssing
Bnd stRiking thc plllintlff, Rnd from hnrassing her relntives.
~
,'-"',
9. The plaintiff desires that the defendant be restrained from entering
her place of employment or the day care fae! Ilty of the minor child.
10. The plaintiff desires that the defendant be enjoined from removing,
damaging, destroying or selling any property owned jointly by the parties or
owned by the plaintiff.
B. EXCLUSIVE rosSF.SSION
It. The apartment from which the plaintiff is asking the Court to exclude
the defendant is rented in the names of the plaintiff and the cefendant. The
defendant has family and friends In the area with whom he can stay,
12. The plaintiff desires possession of the apartment so os to give the
greatest degree of continuity to the life of the child.
13. The plnlntlff desires the defendant to provide suitable alternate
housing for her and the minor child,
C. A'I'TORNF.Y FEFll
14. The plaintiff asks that the defendant be ordered to pay reasonable
attorney fees to Legal Services, Inc.
D. 1'I'JlroRARV CUS100Y
IS. The plaintiff seeks temporary custody of the following child:
HAIIIl
Present Residence
bS.
Samantha J. Hoover
1302 Pine Street
New cumberland, PA
2 years old
DOn: April 7, 1993
The child was born out of wedlock.
The child is presently in the custody of the plnlnt!ff, Linda A. orris, who
is temporarily residing at 1302 Pine Street, New CUmberland, Cumberland County,
Pennsylvania,
1""'\
.~
Since hor bi rth the child has resided with the following persons and at the
following addresses:
NMIl
Plaintiff, her mother,
patricia Orris, and her
boyfriend, Paul Houck
Plaintiff and defendant
Plaintiff, defendant,
plaintiff's mother and
her boyfriend
Plaint I ff and ,Iefendant
Plaintiff, her father,
and her step-mother
Addresses
DIlill
1302 Pine street
New Cumberland, PA
Octobcr 12, 1995
to the prcsent
322A Rcno Street
New ('umberlanel, PA
August of 1995
to Octobcr 12, t995
1302 Pine Street
New ('umhe I' I and, PA
August of t994
to August of 1995
Marshn II Dr I vc
('nmp II I II, PA
May of 1994
to August of t994
January of 1994
to May of t994
October of 1993
to January (If 1994
2115 south Front Street
Stec I ton, PA
Plaintiff, defendant,
defendant's sister, Carol
Dlbetteto, and her son, Derrick
3rel Strcet
Stee I ton, PA
Plaint I ff and defendant
50.19 Trent Roael
Hsn i shurg, PA
April 7, 1993
to Octoher of 1993
The plslntl ff I the mot her of the child, is Linda A. Orris, tcmporarlly
residing at 1J02 pine Street, New Cumberlllnd, Cumberland County, Pennsylvania.
she Is single,
Thc plslntlff cllrrently resilles with the following persons:
Relnt lunshil)
HlIIIIl
Samanthn J, Hoover
Pntrlcill Orrl/l
Psul HOlick
her dnughter
her mother
her mot her's boyfriend
The clefcml/lnt, the f/lther nf the child, ill Robert J, Hoover, Jr" currcntly
resides at 322A lIenn Street, New Cumherlllml, l'umherlnnd (',Clunty, Pennsylvania.
lie 1/1 /lIngle,
Thc dcfel\ll/lllt currl'lIt Iy re/llolcH /lInne,
'"""
,,-...
16, The plaintiff has not previously participated in any litigation
concerning custody of the above mentioned child in this or any other Court,
17. The plaintiff has 110 knowledge of nny custody proceedings concerning
this child pending before II court in this or I1ny other jurlsdlct lon,
18. The plaintiff does not know of any person not n party to this action
who has physical custody of thc child or claims to hnve custody or vlsilat ion
rights with respect to the child,
19, The best interests and permancnt wel fare of the minor child will be
met if custody is temporarily grant cd to the plaint i ff pcnding a hearing in this
matter for reasons including:
a, The plnintiff is II responsiblc parent who cnn best
take care of the minor child and has provided for the
emotional nnd physicnl needs of the child since her
bIrth,
b, The dcfcndnnt has shown by his abusc of thc
plaIntiff that hc is not an npproprlatc rolc modcl for
the mInor child.
c. Tbe dcfcndnnt hilS shown by his abuse of thc chi Id
that he Is not a responslblc parcnt nnd his nct ions have
hnd nil IIdvcrsc effect 011 thc chile!.
WHEREFORE, pursuant to the pnwislons of the "Protectiol1 from Abuse Act"
of Octoher 7, 1971i, 23 P,8. ft litOI et sco., liS nmendml, the plnintlff prays this
Honorable Court to grant thc follnwing rul iuf:
A. Grant II Tcmpllrllry ordcr pUrSUlll1t tn the "Protuction from Abusc
Act :11
."
1. Ordering the defendant to refrain from abusing the
plaintiff or the minor child 01' placing them in feuI' of abusel
2. Ordering the defendant to rcfrain from having IIny dircct
or indircct contact with the plllintiff inclUding, but not
I imlted to, telcphone and wri t ten communicat iOI1l11
3, Ordering the .lcfendant to refrain from harassing and
stalking the plnint I rr nnd from harassing her relat ivesl
4, Prohibiting the defendant from cnterlng thc plaintiff's
plllce of employment or the dllY care fllei II ty of the minor
childl
S, Prohibit ing thc defendllnt from removing, dllmaging,
destroying or selling property jointly owncd by the parties or
owned by the plaintiffl
6, Oranting possession of the IIpnrtment locnted at 322A
Reno Street, New CUmberland, CUmbcrland r.ounty, Pennsylvania,
to the plllintiff to the exclusion of the defendant pending a
final order in this mattefl
7. Ordering the defcndant to stay nway from thc plllintiff's
current residence or nny residcnce the plaint iff may in the
future estnblish for hcrself;
8. Ordering the dcfendant to providc suitllble Illlel'llnte
housing for the plllintiff IInd thc minor child, and
9. Grunt Ing tcmpoJ"nry custody of the minor child to the
plaintiff.
~
B, Schedule a hearing In acconlnnce with the provisions of the
"Protect Ion from Abuse Act I" ancl, after such hellrlng, enter /In order to he In
effect for /I period of one yellr:
I, Ordering the defcndant to refrain from abusing the
plaint i rr or the minor chi Id or placing them in fear of abuse.
2. Ordering the defendant to refrain from bnvlng IIny direct
or Indl rect contact with the plaintiff including, but not
limited to, telephone ami wrlttcn communicntions.
3. Ordering the defendant to refrain from barasslng and
stalking the plaintiff an,1 from harnsslng her relatives.
4. Prohibiting the defendant from entering the plaintiff's
place of employment or the day cllre facll (ty of the minor
child.
S, Prohlhl t Ing the defendant from removing, damaging,
destroying or se Illng property jointly owned by the pllrt ies or
owned by the plaintiff.
6. Ornntlng possession of the IIpartment located lit 322A
Reno Strect, New Cumberlllnd, Cumherland County, Pennsylvania,
to the plaintiff to the exclusion of the defendant.
7. Ordering the defendant to stay nway from the plaintiff's
current residence or any rcsidcnce the plaintiff may in the
future cstnhl i/ih for hersclf,
8, ordering the dcfcndant to provide suitable al ternatc
housing for the plllintl ff ami the minor child,
9. Ordering the defcl1llllnt tn pay re/lson/lhle attorney fees
to Legal Services, Inc.
MONweALTH F PIiNNSVLVANIA
,
COUNTY OF: CUf4I1BRLAND
....,.,....
17065
PETITION FOR EMERGENCV
PLAINTIFF RELIEF FROM ABUSE
r ~/l1)xL q i)j[f;u
3J~ d.. r)€nO ,)1" () 4
L ',flew (!.,J.,d>>fJ..;EIJ.JJr16/ 1(1.. / fO'm
~FE;rNT: ~~",,~~:an~
(-<PlPttr (})UEf.., ;"
8/);)" cJ. <:'(10 '5f- f)
L JIlEltJ &(()lIbE1.tJ7I?j,l~
Dock81 No,:
--
Dale FlIed: iD ~(3- q~
.,
09-3-03
OJ N... f~
SUSAN 1<. DAY
~. 229 HILL STREET, BOX 167
HT. /lOLLY SPRINGS, fA
,_ (717) 406-7672
.,
.J
I 0 PlAlNnFF A!QUl!8T1 CONFIDENTIALITY Of
PfflMAN!HllT!MPOHARY ADDRua,
PETITION OF TliE PLAINllFF
I. , hereby pelttlon lor emergency relief Irom abuse
,""" Plf,.... . p.... ~JJtt
~ behalf 01 mysell
:.-er on Ilehal/ of the loIlowlng (child) (children) to whom I em II (parenl) (adult household member) (gUa~lan)
o no bl!!Jal/ 01 the lollowlno Inco pelln~_adullto whom I am gla.~~an1 Rt.. <'I IlL A \
, ~ (~ __nD !..L...LltLtJ IrrN1iJ1/JjJ,
P'M't1 ~"..
,-,
1o'M""~
Emerg.ncy r.II.llrom .buI. II required bec.uI. Iher.11 Immedl.l. .nd prllenl ding or 01 AbuII bV Ih.
def.nd.nt 10 (ml) Ind 10 Ih_ dov.lIll.d (child) (children) (Inoom 1,.dull).
(Type IddMlonol narne".ddr..... on . ..p.rala
.haII 01 paper and a"'" ""alo,1 '
FINDINGS OF ISSUING AUTHORITY AI an ex parte hi Ing I , c
....a1 hIVe found upon good callll thalli Is nece.aery 10 protect the p ntlfl) and abova listed c I
(Incompetent adulI),
CI I hIve NOT round that II Is necessary to Issue 8 protective order
ACTION OF IBSUING THO ITV
Having 'ound upon good cause shown th811tls necesllry to protect the (plaintiff) and above IIstlld (
(incompetenl adull), I havs taken the 'ollowing acllon on this petition:
_ .2I"Ordered the defandllntlo refrain .rom abusing the plein'," and/or minor child, children, Incompe
o Ordared the ovlctlon 01 the defendant 'rom the (household) (reslden ) (and)
lJ O/derallJ restoration 01 posselllon to Ihe (hollsehold) (residence) a (01)
o Allowed Ihe delendantlo provide sulls!Jle. ollemats housing by 0 elnlll
ORDEns OF 0 EVICTION AND 0 RE8T RATION OF POSSES 10
fa: (Shariff) (Conatable) (P oe Onlcer) (Pollee Depart me , In compliance wllh
he ordar(s) lIppoarlno above, you ora horeby dlrocled 0 10 evict
rom the pr.mlsee at
fNMIt 01 (l.{mlUnlj
(and) 0 to reslore premlsee
\
~."t.I
11
to
~I''''l
lHan~"'PI'I"~'"
rt~r...".~",;'"lhlW""l
NOTICE TO DEFENDANT
O,d." I..u.d ala pu"u.nt 10 1lI0 P,oll.llon f,om IIbu.. Acl. Acl No. 211118T81, II am.nd.d WARNING' failuralo comply wllh th... old"l m.y
I.,U" In n Ilndlng 01 CnlUIIllL CONffUPT pur.u.nllo 42 Pa,C,a, 1141 17. Thl. o".n.. I. punl.h.bra by alln. andlo' ,mpll.onm.n! Th... Old...
..p'" allh. .nd ollhl n..' bu.ln... day 1110 coun dum. 11,,11 .v"I'~I.. Th." o,d." ...11 bl Immodl.I.ly ..n,lI.d 10 Iho coun 01 Comlon Pl...,
'.., "r I~ I~A8 THE EFFECT OF COMMENCING PROCEEDINGS AGAiNST vOU UNDER THE AIIOVE MENTIONED ACT
ex 1-4113IT A
):.,.-1
LINDA A. ORRIS,
Plaintiff
for herself and on behalf of
her minor child,
SAMANTHA J. HOOVER,
v.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 95-6112 CIVIL TERM
PROTECTION FROM ABUSE
ROBERT J. HOOVER, JR.,
Defendant
PROTECTION ORDER
AND NOW, this S~ day of December, 1995, upon consideration
of the Consent Agreement of the parties, the following Order is
entered:
1. The defendant, Robert J. Hoover, Jr., is enjoined from
physically abusing the plaintiff, Linda A. orris, and/or the minor
child, Samantha J. Hoover, or from placing thelll in fear of abuse.
2. The defendant is enjoined from having any direct or
indirect contact with the plaintiff including, but not limited to,
telephone and written communications, except that the defendant may
telephone the plaitiff at her place of employment for the limited
purpose of facilitating custody arrangements.
3. The defendant is ordered to refrain from harassing and
stalking the plaintiff and from harassing her relatives.
4. The defendant is prohibited from entering the plaintiff'S
place of employment or the day care facility of the minor child.
5. The defendant is prohibited from removing, damaging,
destroying or selling any property owned by the plaintiff or
jointly owned by the parties.
6. The defendant is l~t\UI~lo~ the plaintiff'e residence
located at 322A Reno Street, New Cumberland, Cumberland county,
Pennsylvania, except for the limited purpose of transferring
custody.
7. The defendant is ordered to stay away from any residence
the plaintiff may in the future establish for herself, except tor
the limited purpose of tranSferring custody.
B. Court costs and fees are waived.
9. This Order shall remain in effect for a period of one (1)
year and can be extended beyond that time if the Court finds that
the defendant has committed an act of abuse or has engaged in a
pattern or practice that indicates risk of harm to the plaintiff.
This order shall be enforceable in the same manner as the Court's
prior Temporary Protection order entered in this case.
10. This Order may subject the defendant to: i) arrest under
23 Pa.C.S. 56113/ ii) a private criminal complaint under 23 Pa.e.s.
56113.1; Hi) a charge of indirect criminal contempt under 23
Pa.C.S. 56114, punishable by imprisonment up to six months and a
fine of $100.00-$1,000.00; and iv) civil contempt under 23 Pa.e.s.
56114.1.
11. The New Cumberland Police Department shall be provided
with a certified copy of this Order by the plaintiff's attorney and
may enforce this Order by arrest for indirect criminal contempt
without warrant upon probable cause that this Order has been
violated, whether or not the violation is committed in the presence
of the police officer. In the event that an arrest is made under
this section, the defendant shall be taken without unnecessary
delay before the court that issued the order. When that court is
LINDA A. ORRIS,
Plaintiff
for herself and on behalf
of her minor child,
SAMANTHA J. HOOVER,
V.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 95-6112 CIVIL TERM
PROTECTION FROM ABUSE
ROBERT J. HOOVER, JR.,
Defendant
CONSBNT AGRBENEHT
This Agreement is entered on this
';}'1 ~ day of November,
1995, by the plaintiff, Linda A. Orris, and the defendant, Robert
J. Hoover, Jr. The plaintiff is represented by Joan Carey of LEGAL
SERVICES, INC., the defendant is unrepresented but is aware of his
right to have an attorney. The parties agree that the following
may be entered as an Order of Court.
1. The defendant, Robert J. Hoover, Jr., agrees to refrain
from abusing the plaintiff., Linda A. orris, and/or the minor child
or placing them in fear of abuse.
2. The defendant agrees not to have any direct or indirect
contact with the plaintiff inclUding, but not limited to, telephone
and written communications, except that the defendant may telephone
the plaintiff at her place of employment for the lilllited purpose of
facilitating custody arrangements.
3. The defendant agrees not to harass and stalk the
plaintiff and not to harass the plaintiff'S relatives.
4. The defendant agrees not to enter the plaintiff'S place
of employment or the day care facility of the minor child.
5. The defendant agrees not to remove, damage, destroy, or
sell any property owned by the plaintiff or jointly owned by the
parties.
6. The defendant agrees to stay away tram the plaintiff's
residence located at 322A Reno street, New Cumberland, Cumberland
County, pennsy 1 vania, except for the limi ted purpose of
transterring custody.
7. The defendant agrees to stay away from any residence the
plaintiff may in the future eetablieh for herself, except for the
limited purpose of transferring custody.
8. The defendant, although entering into this Agreement,
does not admit the allegations made in the Petition.
9. The defendant understands that the Protection Order
entered in this matter will be in effect for a period of one (1)
year and can be extended beyond that time if the Court finds that
the defendant has committed an act of abuse or has engaged in a
pattern or practice that indicates risk of harm to the plaintiff.
The defendant understands that this Order will be entorceable in
the eallle manner as the Court's prior Temporary Protection Order
entered in this case.
10. Violation of the Protection Order may subject the
defendant to: i) arrest under 23 Pa.c.s. 561131 H) a private
criminal complaint under 23 Pa.C.S. 56113.11 iH) a charge of
indirect crilllinal contempt under 23 Pa.C.S. 56114, punishable by
illlprisonment up to six months and a fine of $100.00-$1,000.001 and
iv) civil contempt under 23 Pa.C.S. 56114.1.
11. The defendant and the plaintiff agree to the entry of an
Order providing for the following custody schedule for their child,
Samantha J. Hoover.
a) The mother will have primary physical and legal
custody of the child.
b) For a period of four wesks after the entry of the
Protection Order and for a longer period if the father
does not obtain housing to accommodate the child by the
end of that period, the father will have partial custody
of the child Sunday from 2:00 p.m. until 6:00 p.m. and
each Tuesday from 5:30 p.1II until 8:30 p.m.
c) After the initial four-week period, if the father
establishes safe, clean and stable houeing for himself
which can also accommodate the child for overnight
periods, the father may begin a schedule of partial
custody on alternating weekends from Friday at 6:00 p.m.
until Sunday at 6100 p.m., and st sny other times
mutually agreed upon by the parties.
d) The parties will alternate the following holidays
frolll noon until 9:00 p.m.: New Year's Day, Easter,
Memorial Day, July 4th, and Labor Day. The father will
begin the holiday schedule with New Year's Day in 1996.
e) The parties will share the Thanksgiving Day holiday
with the father having the child from 4:00 p.m. until
9100 p.m.
f) The Christmas holiday will be shared by the parties
on an alternating basis each year, one parent having the
child on Christmas Eve from 6:00 p.m. until Christmas Day
at 1:00 p.m. and the other parent having the child on
Christmas Day at 1100 p.m. until 9:00 p.m. However, if
December 26th falls on a weekend day in years the father
has the child on December 25th, or if he has December
26th off from work, he may keep the child overnight and
return her to the mother at 1:00 p.m. on the 26th. The
father will have the child on Christmas Day from 1:00
p.m. until 9:00 p.m. in 1995.
g) The father will have a four hour period of partial
custody with the child on the child's birthday each year
at times mutually agreed upon by the parties.
h) The father will have the child on Father's Day from
10:00 a.lII. until 6:00 p.m., and the mother will have the
child on Mother's Day. If the child is in the father's
care, the child will be transferred to the mother's care
at 10:00 ..11I.
i) During his periods of partial custody with the child
the father will not alter her appearance (~. get the
child's hair cut, have the child tattoed, or pierce the
child's ear or any other part of her body) without the
written permission of the mother.
j) The father will provide transportation during his
periods of partial custody.
k) The father will not use drugs and/or alcohol prior
to or during periods of partial custody with the child.
1) The mother and father, by mutual agreement, may vary
from this schedule at any time, but the order will remain
in effect until either party petitions to have it
changed.
LINDA A. ORRIS,
Plaintiff
for herself and on behalf of
her minor child,
SAMANTHA J. HOOVER,
v.
1 IN THE COURT OF COMMON PLEAS OF
:
: CUMBERLAND COUNTY, PENNSYLVANIA
:
: NO. 95-6112 CIVIL TERM
1
1 PROTECTION FROM ABUSE
ROBERT J. HOOVER, JR.,
Defendant
CUSTODY ORDER
AND NOW, this ~~ day of December, 1995, upon consideration
of the parties' Consent Agreement, the following Order is entered
with regard to custody of the parties' child, Samantha J. Hoover.
1. The plaintiff, hereinafter referred to as the mother,
shall have prilllary physical and legal custody of the child.
2. The defendant, hereinafter referred to as the father,
shall have partial custody of the child as follows: for a period of
four weeks after the entry of the Protection Order and for a longer
period if the father does not obtain housing to accommodate the
child by the end of that periOd, the father shall have partial
custody of the child Sunday from 2:00 p.m. until 6100 p.m. and each
Tuesday from 5:30 p.m until 8130 p.m.
3. After the initial four-week period, if the father
establishes safe, clean and stable housing for himself which can
also accommodate the child for overnight periods, the father may
begin a schedule of partial custody on ~lternating weekends from
Friday at 6:00 p.m. until Sunday at 6:00 p.m., and at any other
times mutually agreed
4. The parties
upon by the parties.
shall~~~IJl ~e following holidays
from
noon until 9:00 p.m.: New Year's Day, Easter, Memorial Day, July
4th, and Labor Day. The father shall begin the holiday schedule
with New Year's Day in 1996.
5. The parties shall share the Thanksgiving Day holiday with
the father having the child from 4:00 p.m. until 9100 p.m.
6. The Christmas holiday shall be shared by the parties on
an alternating basis each year, one parent having the child on
Christmas Eve from 6:00 p.m. until Christmas Day at 1:00 p.m. and
the other parent having the child on Christmas Day at 1:00 p.m.
until 9:00 p.lII. However, if December 26th falls on a weekend day
in years the father has the child on December 25th, or if he has
December 26th off from work, he may keep the child overnight and
return her to the mother at 1:00 p.m. on the 2tith. The father
shall have the child on Christmas Day from 1:00 p.lII. until 9:00
p.lI. in 1995.
7. The father shall have a four hour period of partial
custody with the child on the child's birthday each year at times
lIutually agreed upon by the parties.
8. The father shall have the child on Father's Day from
10:00 a.m. until 6:00 p.m., and the mother shall have the child on
Mother's Day. If the child is in the father's care, the child
shall be transferred to the mother's care at 10:00 a.lII.
9. During his periods of partial custody with the child the
father shall not alter her appearance (~. get the child's hair
cut, have the child tattooed, or pierce the child's ear or any
other part of her body) without the written permission of the
mother.
10. The father shall provide transportation during his
periods of partial custody.
11. The father shall not use drugs and/or alcohol prior to or
during periods of partial custody with the child.
12. The mother and father, by mutual agreement, may vary from
this schedule at any time, but the order shall remain in effect
until either party petitions to have it changed.
13. The father shall notify the mother of all medical care
the child receives while in his care. Each parent shall notify the
other immediately of medical emergencies which arise while the
child is in that parent's care.
14. Neither party shall do anything which may estrange the
child tram the other parent, or injure t~e opinion at the child as
to the other parent or which may hamper the free and natural
development ot the child's love or respect tor the other parent.
By the Court,
:~~f~~e~y~;~!!dent
Judge
Joan Carey
LlGAL ."VICIS, IHC.
Attorney for Plaintiff
, T~~E COpy FROM RECORD
n To"lImflllY \'.Ihoreilf, I hure IJnlo sel my hand
and tho EJ!Jf 01 ::ald Cou III Carllskl ....
T"- da ' .... .,'
,...
Robert J. Hoover, Jr.
Defendant
~
n) On UI' nboul octohel' lfi, 1IJ1J5, the c1efenrlnnl telephoned the
(llalnt iff nml thl'elltenell lhllt he wonhl "gel" her 11",1 lhut she would
"pny" enuRing her to felll' for her slIfl'ly,
h) On 01' IIIK1\J1 Octolll'r 12, 1'1'15, Ihe l!l'fl'mlllnt grnhhed lhe
pllllnlfff's CIII' kl'Ys, twll<lell thc ke}'fl her flngcrl< which were
entwined in the key ring, 111,,1 henl 1mI' lhllmh h/lck c/lusing the
plulnt iff p/lin, The plllinll ff lefl her residence thllt night for her
own proll".tion IIn,1 tOllvoid further IIhuse IInd hilI< nol relurned, The
fol lowing II/lY the pllllnll ff sllIlght IIn emergency p/'lltect ion order
from nisll'icl ,Jusl Ice !lilY (see III tnched Exhibit A, incof"(KlI'nted hy
reference) .
c) On or nhollt Sept cmhl'J' .10, 19'15, the dl'feml/lnt grnhhf'd l he
pllllntiff's Ul'm, lorc her shirl, nllll threw Iwl' onlo the lovesell!.
The defendllnt then grllhlll'd thc plnlntlff's hiliI' und demnnded thnt
she tell him where she hllll heen, The pllllnll ff I<uRtnlned II
IlIcernllon on hcr wrist IInd soreness IIhonl her IIrm and helld liS n
l'eHull of this Inci<lenl.
d) On or nholll Sl'ptcmher 24, 1'llJ5, the dcferlllnnl followed tbe
pllllnt iff nhout the house, pul his fist In the pllllntlff'fl fllce
hetween her cyes, IIIlll lhrenll'IlCd her sllylng. "I'll knock you outl
I'm relldy In punch YOUl Vou'"c long oVI'l'lluc" clluslng the pllllnt Iff
to felll' for her sllfety,
e) In or uhnut Muy of 1'1'15, the dd.'ndunt pushed till' plulntlff
down onlo u stcp cuuslnl! 111'1' to strikt' Illlt rll'ck IIml huck, As n
result of thll< Incill"llt thc "llIlnt Iff hll,1 I Imltcll mohlllty of Iwl'
neck and BOrenl!SS IIhout her neck Rnd hllCk, and Hhl! required medical
nllenllon,
f) In or about MIlY of 1'194, till! defellllnnt grllhhed the (lllllntl ff
by hol' hR11' hllnet 111111 threw her tll the grnUl1<1.
8) In or IIhout I'I'IJ, on se(llll'lIte Ilccllsions the ,Ieft'nrlllnt tried tn
shove the (lllllntlrr ,Inwn II flight of 1I(l(lroximlltely 17 sllllrs Ilnd
Rllem(ltcrl to (lush t1w (lllllntirr's heRd through II window while she
held the (lllrt it,s' 3 "KlI1th-old hllhy in her IIl'ms.
h) Since Il(l(lrnximntely Augusl of 1'1'1,1, the defellllRnt hns IIhused
the (llllinllff III WIlYS incluolilll!, hut lint limited 10, pushing,
shoving, (lulling her hnir, throwing her Rhout. In ncldltlon, the
rlefcr1<lnnt hilS violenlly shllkell the (llll'tles InfRnt dllughler nil II
numhel' of Ilccllsfons,
~. On or IIhout Octohcl' 12, 1'1'15, II\(' (llllint Irr nn,l the minor chi Id left
their residence lit J22A Ilenll St f<'el, New {'umher1IIIllI, Cumherllll1ll Cnunty,
PennsylvRnlll, In order 10 IIvold further IlhuSt',
Ii. Thc plllinllff hlJl ievt's 111111 therefllre livers thlll .she 811<1 the minor
chi Id nrc In immedlllte 11I111 (lrest'llt dllnger of Ilhuse from the ,Iefendllnt should they
return tn the ho"lI' withnut Ihe defel1llllllt's exclusloll 111111 lhllt Ihey lire In need
of (lflltectloll from such nhuse,
7, The plllllltirr desires thllt Ihe .ldel1llllnt he (lrnhihited from hllVtll1!
IIny direct 01' Irllllrect conlllcl wllh tl\(' [ll/llnt Iff Inl'lu,llllg, hut lint Ilmftml tn,
telephone IIml writ ten cnmmUIl !ell I Inlls,
R. The (llllintiff ,I,'sil'es thlll Ihe ,1l'f"llIllIllt he elljntr1l'c1 frnm hllrllllllillg
11I1<1 1IIIllklng II\(' [lllllnt Iff, /11111 fro", hlll'/llIslng her H'llIt ives,
Iii. The plnlntlff hns not previously l'nrliclpntud In Rny II t Igntlnn
concerning custolly of thu nbnvu IIIl!11tlnl1l'1I child In thlll nr nny nthur Cnurl.
17. The plltlntlrf hits nn knnwledgl! nr nny cUlltn,ly proceedingll cnncurnlng
this child (lelullng hufnre II cllurt in Ihlll nr /lny other jurilldicllnn,
IH. The 1'I/lIntl ff .llles nllt kllnw nf nllY persnll lint II pnrty to this ncllnll
whn hns l'hysil'nl clIstlllly of the chi lei or clnlms tn hnve CUlltnlly or visltllt inn
rights with respecl tn the chi Id,
19. The best Interests /11111 permllllent welfnre nf the minnr chi 1,\ wi II be
met If custndy III tempnr/lri Iy grnllt",1 tn the I'lnfnt iff pendlllg n henrlng In thill
m/lt ter fur rensons Including:
/I, The plnlntlff is n nlspnnsihle pnrenl whn cnn best
l/Ike cnre nf the IIIlnllr chll,1 111111 hns prnvlded fill' the
elllnt fnnnl nn,1 I'hys lenl ne",ls of I he ch lid since her
hlrth.
h. The IlefelUl/lnl hilS shown hy his nbllsl' of th"
plninl Iff 1I1111 he ill nnl nn npprol'rlnle role mmlel fnr
the mlnnr chi Id.
c, The dd"lul/llll hilS showlI hy his nhuse Ilf the ch 11e\
1I111t till Is lint n I"SIKll1sihle l'nrent nl1ll hill /let 11ll1s hnve
hll'\ /III n,lverse ""r.'d <Ill Ihe chi III.
II1lf.RI\FORE, tlUrSllnll1 111 the plllvisiollS of Ihe "pl'llll'cllllll flllm Ahulle Act"
of octnher 7, IlJ7li, 231',:;, " (,10\ .,,1 !il,!!1., ns nlllellll"d, till' 1'1111111 Irf prllYs Ihls
lIonnrnble {'nUl'l 10 grullt the following 1,,1 il'f:
A, 0111111 II Tl'III1K,rulY order pllrslllllll III lh,' "I'rotl'clllln frllm Abllllc
Act: II
,
I. Ordering the clt'fendunt to refrnin from abusing the
plnlnllff or the minor child nr placing lhem in fenr of nhuse;
2, Ordering tlw defellllnnt tn refrnin from hnving nny direct
or 111lllrect cnntncl wilh the pllllnliff including, hut not
limited to, telephnrw IIml wri I ten cnmmunicllt inns;
3, Ordering the defelllhllll In I'efrllin from hllrnsslng 11I111
stRiking the plllinll ff nnd from hllJ'nsslng her relnl ivesl
4. Prohihlting the clefcllllllnl fl'nm entering the plnintiff's
plllce nf employmenl or the dllY cnn, fllei Illy of the minor
child;
5, Prohihi t inl! the defendRlll from remnvlng, dnmllging,
deHtroylng nr selling property jnintly nwned by the pnl'lles or
owned hy the pili lnt iff;
6. Ornnt ing possl'sHinn of the npl\rtml'nt locnled lit J22A
Reno Street, New C'umber I 11I111 , C'umherlnl1ll C'nunty, Pennsylvllniu,
to Ihe plnlnl I 1'1' In the exclusion of the defendnnl (ll'mling II
I' Irlll I nnll'l' in this millieI'!
7, Onll'rll1g the Ilefl'l1llnnl tn stny nwny from lhl' (lllllnllff's
currel1t residence or /lilY I'esirll'nce lhl' (llnlntlff mny In lhl'
future l'stnhlish for Iwrself;
R, Onll'l'il1!! lhl' Ih'fel1llnl11 III pl'nl'ldl' sl1ilnhll' IIIll'nlnte
hnuslng fill' the plnlnllfr 111111 the minnr child, 11I111
9, l1rllnlll1g Il'm(l""lIr~' l'ustnely of the minor chi hi tn the
pllllntl 1'1',
- --~.....
_ _ ~'_' --. ','; t- , ,
IJ, Schedule II hearing In IIcconlllnce wilh the Ilrovlslons of the
"Protection from Abuse Act," 1I1ll1, lifter Huch heRring, enter IIn order to be In
effect for II pcrlod of one yellr:
t. ordering the defendllnt to refrain from nbusing the
pllllntlff or the minor chi Id or plllcing them In fellr of IIbuse,
2, ordering the defendllnt to refrllin from hnvlng any direct
or Indirect contnct with the plalotiff including, but not
I imited to, telephone and written communiclltions.
3. ordering the defendllnt to refrain from hnrasslng and
stalking the plnlntlff nnd from hnrasslng her rellltives,
4, Prohibiting the defendnnt from entering the pllllntlff's
plllce of employment or the dllY cure fnei I ily of the minor
child,
5, Prohihiting the defendllnt from removing, damaging,
destroying or sell ing property joint Iy owned by the parties or
owned hy the pllllntlff,
(" Orllnl ing possession of the IIpllrtment locnted lit 322A
Reno Strec\, New rumberlllnll, rumherlllnd l'ounty, Pennsylvllnill,
to the pllllnllff 10 thc exchlsioll of the defendllnt,
7, Ordcrlng Ihe defellllllnl to stllY aWIlY from Ihe plaintiff'S
currenl residence or III1Y resltlence thu pllllntlff mllY In the
future efltllbllsh fur hel'sel f.
R, onh,rlng Ihe llefl'nlllllll to prnvlde suitllhle IIlternllte
housing for II", plllintlrf IIn.lthl' minor dllld.
I), Orrll!l'lng thl' defl'ndllnl to P"y n'"801lIhle IIl1nrrll'Y fees
to I.eglll SCl'vices, Ine,
PETITION FOR EMERGENCV
PLAltHlrF RELIEF FROM ABUSE
r ~/l1!xL ~ujs;'U
3;)9.. (l.. nE:nt) ::>r. n
L '11'f:.w (!.J.u;tt?Jf.wl1l6 ( /(1 '- I~ 0 'm
~rE/rT t"- ~'~:ro~7f
(-<:1~l!>ttr c'OvO.., R.,
g:K). a. aiD '51-, f)
L (lELu (!).I(1tlbt1.(JlI1~, f.-Q.
Dockel No,:
DolO Filad: 10 -(3- q{'
",MMONWEALTH OF PIiNNSVLVANIA
, .
COUN1Y OF: CUMBERLAND
~'" ""'""
09-3-03
OJ NIIN ltun,
SUSAN 1<. DAY
_... 229 MILL STREET, DOl( 167
HT. HOLLY SPRINGS, PA
''''''..... 17l7l 406-7672
17065
'"1
'"1
.J
I 0 PLAINTIFF REQUESTll CONFIDENTlALlll OF
PERMAIlEN1ITEMPOHARY ADORUll.
PETITION OF THE P~INT1FF
I. . hereby pellllon lor emergoncy rellellrom abuse
"'&/!'If of ~I/lt"', p." ....,.1
hn behell Dt mysell
~ on behall ollhe followlno (child) (children) to whom I am a (pa.renl) (odullllOusehold member) (gUa~ian)
o on behalf ollhe lollow,hlO tnc?'l'petent adult to whom I am O.\!,a.rdian 1~ <' I 1(\..., . \
:'Yl~'lct ' 3:.).,:} (L _~t1C\ ~tJ IrlAft1J1@
,..",., ",..lint..,
(AoWt.U~
Emergency rell.1 Irom .bu,' I. required bec.u.. th"eIe lmmedl.t. .nd preeen\ d.ngnr 01 .buee by Ih.
d.I.nd.nt to (m.) .nd to the .bove lilted (child) (children) (Inoom I t ..dull).
(Tvpe .dd~lon" n.m.aI.ddl..... on . 101'.'.11
ohMI 01 P'P" .nd ouoeh h.ltlo,l .
jU""'1
FINDINGS OF ISSUING AUTHORITY At an ex pane heB Ing I , ' 7
,..a1111ve lound upon good cause that Ills necessary to protect Ihe p nlllf) and above listed c UCl) (child en)
(lncompelent adull), 'i
CI I have NOT found Ihat It Is necessary to Issue B protective order '
lut.oJ " \ll'~ . --
ACTION OF ISSUING THO ITV ,/
Having found upon Onod cause shown Ihallt Is necessary 10 prolect the (plalnllff) and above listed (Q)(ild) (childran)
(incompetent adult),1 have takenlhe lollowing Bcllon on this petition:
_ .2"OrderOO Ihe delendonlto refrain trolll abusing 1110 plalnll" and/or mln~child, c111ldren, Incompe nl
o Ordered Ihe evlcllon ollhe delendanllrom the (household) (reslden II) I '
\l&I.J. I'
o Ordertlllr9slorollon of possesBlon to the (hollsehold) (resldenco) a
o AIIowecllha delllndanllo provide sultaule, ollemate hOl/slng by co sent a
ORDERS OF 0 EVICTION AND 0 REST RATION Of POSSES 10
ro: (Sheriff) (Constable) (P ce O"lcer) (Police Depanme , In compliance wllh
'Ie order(s) appearing abOv!!, you are tlarelly dlreclod 0 \0 eVIc\
rom Ihe premises at
UU",,{jI(le!Ina.nll
(end)
(01)
(and) 0 to restore promlsss
,
i^oJU,t\\1
10
INlln~ClIP\""'I;m
II
l,N:td'"'1
l"~IIAluI.e'''hln9;'''Ih6l1t11
NOTICE TO DEFENDANT
O,dOIOI..u.d.II PUrlu.n! 10 Ih. P,ol,,\lon Irom Abuo. Ael, Ael No. 218 \IUT61," .m.ndod WARNING: flilult te ,omply wllh lh... Old... m.V
10lull In n \lndlaQ.1 cnlMltlAL coNTEMP1 rUllu.nllo 42 r.,C,S,1l41t7, 1hto oflln..I, puntlhobl. bV l\ln. entl/ol Imp,llonm.nt Th.1O .,d...
"1'1'. .1 Ih. .nd .llhI n..1 bUlln.1O daV Iho coun d..ml illOlI QVIII'~la. lh... Old". ",1I11. Immodl.I.lv ,.nillod 10 Ih. Court 01 COnnon PI..o,
.." OIr OJ H'~ THE EFFECT OF COMMENCING PROCEEDINGS AGAINST VOU UNDER THE AOOVE MENlIONEO ACT
E:.X/4I'BIT A
t',
,
.
COMMONWllA/,'I'1! 0/' l'IiNN A I
COUNT" 01' UAU/'IIIN I
SIIER/F/"S RETURN
NO. 95-6112 Civil Term
PAml 66
ANU NOW I
Nov. 8th
10 95 ,lit 2:45 P.M.
SERVEU 'l'IIE
WI'I'IIIN'l'empor!l.!Y ~ction Ord:.; Pro1:ecti~n.1'!~_~buseLNo_tic~_ .!l!lE-___ UPON
l'Cfi11onror lemporary Oruer
UY PERSONALLY
Robert J. Hoover, Jr.
IIAN/lING '1'0 Robert J. Hoover, Jr. Defendant
A TRUli A1''I'ESTllO COPY OF THE OR/UlNAI, Temporary Protection Order Protection fran
Abuse Notice and Petition for Temporary Order
AND MAKINO KNOWN '1'0 him TIlE CONTENTS THEREOF AT the Dauphin
County Courthouse, Front & Market ST. Harrisburg, Pat
SO ANSWERS
I ' cf}' 'C-"
"I--/";((:<';"?f. '-!~V'\^"il ~,,'
---. --_.-.-.-.._...\J_.__h~'~.+-_____
SHERIFF OF DAUPHIN COUNTY, PENNA
UY /I.~(" 1~'4~- ______
~~1'\' SIIEHWf'
Sworn and subscribed to
~'Je~~re mo this 9t1'1av ,Of Nov.
\[ r I, 'I) ,,(1 I ../')' '.' , ,'" \
\-. "l-Hlli, ,...__-. I LvU,)(.,(.{...-'
PHO'l'1I0NOT ARY
19
95
BIlE/IIFI"S COS'/' $ ~
S-IA
I,INOA A, ORRIB,
Plaint I ff
for herse I f and on beha I f of her
minor child, SAMAN'I1IA J, HOOVER,
v.
IN TIlE COURT OF <nMJN PLEAS OF
CUMBERl.AND OOUNTY, P~SVLVANIA
ROBERT J. IIOOVER, JR.,
Oefendant
NO, 95-6112 CIVIL TERM
PROTECTION FRC* ABUSE
ANI> NOW, this
I 0RllIlll fOR aM'INUANCB
/~1-\-
~ day of November, 1995, upon consideration of the
attached Motion for Continuance, the matter scheduled for hearing on Novelber I,
1995, at 9130 a,m.. by this Coort's order of October 24, 1995, is hereby
rescheduled to Oe~r 11, 1995, at 1:30 p... in Oourt ~ No. t.
The Te.porary Protection Order shall remain In effect for s period of one
yesr or until ~Ifled or terminated by the court after notice or hearing.
A certified copy of this order for Continuance will be provided to the New
CUllberland Pollee OepartlllCnt by the plaint Iff' B attorney,
By the Court,
.:' . Lt/<t,.' .L
I arold E. Sheely,
'//~.
sident Judge
Joan carey
LOOAI, SIlRVICF.ll, INC.
Attorney for Plaintiff
. ~:
\01
, ' ; ';J: ~ i j
~
te
,-<",
~l':
<1'1..,:
~II, ~.1.
U... 07:
b:; '..'t~;
v.,. ." ..
".,.- ........
. c .t;"
~ . '-.:t.
.'f' ~- Ii
d~oJ~lhj
" \;';;,IL.
:>
:~ I,.)
,';
Ii
i,l
,..,
It'
'-.l
it"
'i
'1
'1'
'-: If
I ~;( \ 1 j ~.
J;~ I
l!;
:;.:::
,;
" ,!,'
~ ' '
lI'
II i b~
~! . i
',r:!"
". ji
'I~J. ..':! - ,
-.""
",'-
'"
1"1~
J" ";!'
I,"
~ ' i
\j,
1'1
{.,
I:
l;'
L
.,
Ji,'!
. " ;; o,~. 1
.+~"'
. 1 <~ I
i.\"
i-''tk',i
; ,. /,~..
.'
I
l
:,dl'" t
.~. ",
LINDA A. ORRIS,
plaintiff
for herself and on behalf of
her minor child,
SAMANTHA J. HOOVER,
v.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 95-6112 CIVIL TERM
PROTECTION FROM ABUSE
ROBERT J. HOOVER, JR.,
Defendant
. t N PROTECTION ORDER
AND NOW, this ~ day of December, 1995, upon consideration
of the Consent Agreement of the parties, the fallowing Order is
entered:
1. The defendant, Robert J. Hoover, Jr., is enjoined from
physically abusing the plaintiff, Linda A. Orris, and/or the minor
child, Samantha J. Hoover, or from placing them in fear of abuse.
2. The defendant is enjoined from having any direct or
indirect contact with the plaintiff inclUding, but not limited to,
telephone and written communications, except that the defendant may
telephone the p1aitiff at her place of employment for the limited
purpose of facilitating custody arrangements.
3. The defendant is ordered to refrain from harassing and
stalking the plaintiff and from harassing her relatives.
4. The defendant is prohibited from entering the plaintiff'S
place of employment or the day care facility of the minor child.
5. The defendant is prohibited from removing, damaging,
destroying or selling any property owned by the plaintiff or
jointly owned by the parties.
6. The defendant is excluded from the plaintiff'S residence
located at 322A Reno Street, New cumbor1and, cumberland county,
Pennsylvania, except for the limited purpose of transferring
custody.
7. The defendant is ordered to stay away from any residence
the plaintiff may in the future establish for herself, except for
the limited purpose of transferring custody,
B. Court costs and fees are waived.
9. This Order shall remain in effect for a period of one (1)
year and can be extended beyond that time if the Court finds that
the defendant has committed an act of abuse or has engaged in a
pattern or practice that indicates risk of harm to the plaintiff.
This order shall be enforceable in the same manner as the court's
prior Temporary Protection order entered in this case.
10. This Order may subject the defendant to: i) arrest under
23 Pa.C.S. 56113; ii) a private criminal complaint under 23 Pa.C.S.
56113.1; iii) a charge of indirect criminal contempt under 23
Pa.C.S. 56114, punishable by imprisonment up to six months and a
fine of $100.00-$1,000.00; and iv) civil contempt under 23 Pa.C.S.
56114.1.
11. The New Cumberland Police Department shall be provided
with a certified copy of this Order by the plaintiff'S attorney and
may enforce this order by arrest for indirect criminal contempt
without warrant upon probable cause that this order has been
violated, whether or not the violation is committed in the presence
of the police officer, In the event that an arrest is made under
this section, the defendant shall be taken without unnecessary
delay before the court that issued the order. When that court is
LINDA A. ORRIS,
plaintiff
for herself and on behalf of
her minor child,
SAMAIlTHA J. HOOVER,
v.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 95-6112 CIVIL TERM
PROTECTION FROM ABUSE
ROBERT J. HOOVER, JR.,
Defendant
. 1 If CUSTODY ORDBR
AND NOW, this ~ day of December, 1995, upon consideration
of the parties' Consent Agreement, the following Order is entered
with regard to custody of the parties' child, Samantha J. Hoover.
1. The plaintiff, hereinafter referred to as the mother,
shall have primary physical and legal custody of the child.
2. The defendant, hereinafter referred to as the father,
shall have partial custody of the child as follows: for a period of
four weeks after the entry of the Protection Order and for a longer
period if the father does not obtain housing to accommodate the
child by the end of that period, the father shall have partial
custody of the child Sunday from 2:00 p.m. until 6:00 p,m. and each
Tuesday from 5:30 p.m until B:30 p,m.
3. After the initial four-week period, if the father
establishes safe, clean and stable housing for himself which can
also accommodate the child for overnight periods, the father may
begin a schedule of partial custody on alternating weekends from
Friday at 6:00 p.m. until sunday at 6:00 p.m., and at any other
times mutually agreed upon by the parties.
4. The parties shall alternate the following holidays from
noon until 9:00 p,m.: New Year's Day, Easter, Memorial Day, July
t' v:j., IJA. ~ I),\"()~:II'J~ ,l '1 '(.. (71'~--'
I ).141~ I'K-'t' ,"
t , 1\.J1,I.I I ,J1~
1ft
4th, and Labor Day. The father shall begin the holiday schedule
with New year's Day in 1996.
5. The parties shall share the Thanksgiving Day holiday with
the father having the child from 4:00 p,m. until 9:00 p.m.
6. The Christmas holiday shall be shared by the parties on
an alternating basis each year, one parent having the child on
Christmas Eve from 6:00 p.m, until Christmas Day at 1:00 p,m. and
the other parent having the child on Christmas Day at 1:00 p.m.
until 9:00 p.m. However, if December 26th falls on a weekend day
in years the father has the child on December 25th, or if he has
December 26th off from work, he may keep the child overnight and
return her to the mother at 1:00 p.m. on the 26th. The father
shall have the child on Christmas Day from 1:00 p.m. until 9:00
p.m. in 1995.
7. The father shall have a four hour period of partial
custody with the child on the child'S birthday each year at times
mutuallY agreed upon by the parties.
B. The father shall have the child on Father's Day from
10:00 a.m. until 6:00 p.m., and the mother shall have the child on
Mother'S Day. If the child is in the father'S care, the child
shall be transferred to the mother'S care at 10:00 a.m.
9. During his periods of partial custody with the child the
father shall not alter her appearance (L.!!., get the child'S hair
cut, have the child tattooed, or pierce the child'S ear or any
other part of her body) without the written permission of the
mother.
10. The father shall provide traneportation during his
periods of partial custody.
11. The father shall not use drugs and/or alcohol prior to or
during periods of partial custody with the child.
12. The mother and father, by mutual agreement, may vary from
this schedule at any time, but the order shall remain in effect
until either party petitions to have it changed.
13. The father shall notify the mother of all medical care
the child receives while in his care. Each parent shall notify the
other immediately of medical emergencies which arise while the
child is in that parent's care.
14. Neither party shall do anything which may estrange the
child from the other parent, or injure the opinion of the child as
to the other parent or which may hamper the free and natural
development of the child's love or respect for the other parent.
By f(hel(cl~urt\,_:,_
~ ~ _ ~LL
Harold E. Sheely, presid t Judge
. Joan carey
~~ LIOaL BlaVICIS, INC.
t~'\ ;}}...~ Attorney for Plaintiff
'1,,# 1\
. 11-\ ~ Robert J. Hoover, Jr.
piP" Defendant
LINDA A. ORRIS,
Plaintiff
for herself and on behalf
of her minor child,
SAMANTHA J. HOOVER,
v.
IN TilE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 95-6112 CIVIL TERM
PROTECTION FROM ABUSE
ROBERT J. HOOVER, JR.,
Defendant
CONSENT AGREEMENT
This Agreement is entered on this
.~1 'r!:::- day of November,
1995, by the plaintiff, Linda A. orris, and the defendant, Robert
J. Hoover, Jr. The plaintiff is represented by Joan carey of LEGAL
SERVICES, INC.; the defendant is unrepresented but is aware of his
right to have an attorney. The parties agree that the following
may be entered as an Order of Court.
1. The defendant, Robert J. Hoover, Jr., agrees to refrain
from abusing the plaintiff, Linda A. orris, and/or the minor child
or placing them in fear of abuse.
2. The defendant agrees ~ot to have any direct or indirect
contact with the plaintiff inclUding, but not limited to, telephone
and written communications, except that the defendant may telephone
the plaintiff at her place of employment for the limited purpose of
facilitating custody arrangements.
3. The defendant agrees not to harass and stalk the
plaintiff and not to harass the plaintiff's relatives.
4. The defendant agrees not to enter the plaintiff'S place
of employment or the day care facility of the minor child,
5. The defendant agrees not to remove, damage, destroy, or
sell any property owned by the plaintiff or jointly owned by the
parties.
6. The defendant agrees to stay away from the plaintiff's
residence located at 322A Reno street, New Cumberland, Cumberland
County, pennsyl vania, except for the limited purpose of
tranSferring custody.
7. The defendant agrees to stay away from any residence the
plaintiff may in the future establish for herself, except for the
limited purpose of tranSferring custody.
B. The defendant, although entering into this Agreement,
does not admit the allegations made in the Petition.
9. The defendant understands that the Protection Order
entered in this matter will be in effect for a period of one (1)
year and can be extended beyond that time if the Court finds that
the defendant has committed an act of abuse or has engaged in a
pattern or practice that indicates risk of harm to the plaintiff.
The defendant understands that this Order will be enforceable in
the same manner as the Court's prior Temporary Protection Order
entered in this case.
10. Violation of the Protection Order may subject the
defendant to: i) arrest under 23 Pa,C,S. 561131 ill a private
criminal complaint under 23 Pa.C.S. 56113.1; ili) a charge of
indirect criminal contempt under 23 Pa.e.s. 56114, punishable by
imprisonment up to six months and a fine of $100.00-$1,000.00; and
iv) civil contempt under 23 Pa.C.S, 56114.1.
11. The defendant and the plaintiff agree to the entry of an
Order providing for the following custody schedule for their child,
Samantha J. Hoover.
a) The mother will have primary physical and legal
custody of the child.
b) For a period of four weeks after the entry of the
Protection Order and for a longer period if the father
does not obtain housing to accommodate the child by the
end of that period, the father will have partial custody
of the child sunday from 2100 p,m. until 6:00 p.m. and
each Tuesday from 5:30 p.m until B:30 p.m.
c) After the initial four-week period, if the father
establishes safe, clean and stable housing for himself
which can also accommodate the child for overnight
periods, the father may begin a schedule of partial
custody on alternating weekends from Friday at 6:00 p.m.
until sunday at 6: 00 p.m., and at any other times
mutually agreed upon by the parties.
d) The parties will alternate the following holidays
from noon until 9:00 p.m,: New Year's Day, Easter,
Memorial Day, July 4th, and Labor Day. The father will
begin the holiday echedule with New Year's Day in 1996.
e) The parties will share the Thanksgiving Day holiday
with the father having the child from 4100 p.m. until
9100 p.m.
f) The christmas holiday will be shared by the parties
on an alternating basis each year, one parent having the
child on Christmas Eve from 6100 p.m. until christmas Day
at 1100 p.m. and the other parent having the child on
Chrietmas Day at 1:00 p,m. until 9:00 p.m. However, if
December 26th falls on a weekend day in years the father
has the child on December 25th, or if he has December
26th off from work, he may keep the child overnight and
return her to the mother at 1:00 p,m. on the 26th. The
father will have the child on Christmas Day from 1100
p.m. until 9:00 p.m. in 1995.
g) The father will have a four hour period of partial
custody with the child on the child'S birthday each year
at times mutually agreed upon by the parties.
h) The father will have the child on Father's Day from
10:00 a.m. until 6:00 p.m., and the mother will have the
child on Mother's Day. If the child is in the father's
care, the child will be transferred to the mother's care
at 10:00 a.m.
i) During his periods of partial custody with the child
the father will not alter her appearance (~. get the
child's hair cut, have the child tattoed, or pierce the
child'S ear or any other part of her body) without the
written permission of the mother,
j) The father will provide transportation during his
periods of partial custody,
k) The father will not use drugs and/or alcohol prior
to or during periods of partial custody with the child,
1) The mother and father, by mutual agreement, may vary
from this schedule at any time, but the order will remain
in effect until either party petitions to have it
changed.
m) The father agrees that he will notify the mother of
all medical care the child receives while in his care.
Each parent will notifY the other immediately of medical
emergencies which arise while the child is in that
parent's care.
n) The parties realize that their child's well being is
paramount to any differences they might have between
themselves. Therefore, they agree that neither party
will do anything which may estrange the child from the
other parent, or injure the opinion of the child as to
the other parent or which may hamper the free and natural
development of the child's love or respect for the other
parent.
WHEREFORE, the parties request that a protection order be
entered to reflect the above terms.
1
l. /..
Robert
Defendant
. J"', .. ( {
J"; Hoover, Jr.,
( (
plaintiff
I
LIGAL 8IRVICBS, INC.
B Irvine Row
carlisle, PA 17013
(717) 243-9400
~
\
'"
,
~
..{
-
I i ~
i~ :;: ~~
f:: Cl- C!.
q;: If':~-
0:) ,,~~ h\ rn!
~5 ,,, .'l;
(n 0
"1
j
.... ..
CDNIlDlI1fDL'1'Il or .--nftInA
ROBERT J. HOOVER,
Petitioner
CDUII'l'Y or CDIIIII_y,'t.1In
:
.
.
v.
.
.
F i 1 e
N 0
95-6112
LINDA A. ORRIS,
Respondent
.
.
IUBPOBNA TO ATTBKD AKD TBSTI'Y
Doug Glass, Deputy Director of cumberland County Control
CUIIlberland County Prison, 1101 Claremont Road
You are ordered by the court to provide for the following procaedinq at
the CUIIlberland County Courthouse, Courtroom I 4 at Carlisle, CUIIlberland
County, Pennsylvania, on Thursday, December 4, 1997, at 10:00 a' clock, ~
M., on behalf of Robert J. Hoover in the above case.
2. And provide the following: An accurate and correct CODV of the
Tuesdav. November 18. 1997 911 hoe reco~di~~ ~f t"h-;'; t;ie~hone call
originating trom 322A Reno Street. New CUmberlan~. PA. at 22:56 hQU~I. ~be
teleohone nUlllber of origin was 1797\ 774-2941. S~i~ih ~~ll ~e~~~~~d a do~:eetic
disoute. Also with this CODV include anv !.!)d .!__ ~flCI!~.!!!~ntat.!.Q'l CD!!!L~n!na
the accuracv and correctness of said CODY.
If you tail to attend or to produce the docUIIlents or things required by this
subpoena, you may be subject to the sanctions authorized by Rule 234.5 ot the
Pennsylvania Rules of civil Procedure, inclUding but not limited to coats,
attorney tees and illlprisonment.
A PARTY/ATTORNEY IN COMPLIANCE WITH Pa.R.c.p. No. 243.2(a).
M. Pi.c.. SUD8rvi.ina At~orn.v
45 North Pitt Street
Carli.i.. PA 17013
17171 243-2968
lUPREIlE COURT ID #
21052
--DE l' ,} 1997
Soal of thB Ccurt
BY TIlE COURT.
I.~~?r..u f? U )ocJi:, ,/
~rD ~ notary/Clerk, Civil Diviaion
P/J .J ~ ,,'J'"
Deputy
OFFICIlIL HOTE. Thio form of .ubpoBna .hall be ueBd whenever a .ubpoena ie ieeuable.
includlnq heerinqo in connoctlon with dBpooitione and before arbitratore, .a.tero,
commia.ionero, etc. 1n compliance with Pa.R,C.p No. 234.1, If a lubpoBna for production of
documBntl, recorda or th1nQo 1B dBBired, complBte paraqraph 2.
: r r:' '~ II , .
I,
,d-"
"'I
()7 '11",' -', ., II' to"
... f'. ..,,' ......
el)':", , ."If"
n.., : '. '. . ,- 1,_ i
F..:;~. ".:\1.\/:-;....
-
J?
5
r:..;
t
8
u
!3
~
..
.11
..P
%
c:.J
~
~
.... ,~
0 ~\ . m
~ '::
P ~l~tB~
~ -
~ .. ':~~~'3i
~ . ~
-
N III III ~ jB~:~~
c lM r-
~ () ..'-~ -
g ~ , .. ~~.. --..., ~
III ~ 2 ~ .,.,~ 8 "I ,-
.... ,\ "-
III .....c...Pi ~
.. .... Ol 0 u !~...g"'B ~
~ ,0 '~] c-l "-
" ': )~ .. .~ ! ~ "M ,
i ~ 'M
Jl ~... -" . ... <.... ".., .~
., . ..-4
t r _ .e w :, ~....!~~~ ,
l&. 'v ~~ 0' )
0 ,~ " I
(~ Hi);1 ,
I ~ 1 ..
~~ ~
8 .
.... ....~.... 0 ...
SHERIFF'S RETURN - REGULAR
CASE NOI 1995-06112 P
CO""ONWEALTH OF PENNSYLVANIA I
COUNTY OF CU"BERLAND
ORRIS LINDA A
VS.
HOOVER ROBERT J JR
f
!
,
DAVID ZEIGLER . Sheriff or Deputy Sheriff of
CU"BERLAND County. Pennsylvania. who being duly sworn according
to la.. .ays, the within PROTECTION FRO" ABUSE was served
upon HOOVER ROBERT J JR the
defendant, at 16125 HOURS. on the ~ day of ~ovember
19~ at CU"B. CO. SHERIFF'S DEPARTnENT 1 COURTHOUSE SQUARE
CARLISLE. PA 17013 ,CUnBERLAND
County, Pennsylvania, by handing to GAIL C. CALDERWOOAL
~TTORNEY FOR DEFENDANT
a true and attested copy of the PROTECTION FRO" ABUSE
and at the same time directing ~ attention to the contents thereof,
Sheriff's CO.tSI
Dooketing
Service
Affidavit
Surcharge
So answp:-~ '\ ~~ _ ~" '
R. IhOmas :, ~~~ ,"
..,.".... /1 'L
by . /9
. uep. - er :tl
,00
.00
.00
.00
~.'lJ1D
Sworn and subscribed to before me
this ,;J(,!!- day of' I t...L"q..I,~
19 'II A. D.
"-t. L_ C. 11\...-1:..L--
, prothonotary
iJ-f'7 '
,
LINDA ANN ORRIS,
1'lalntlt1'
IN TIlE COURT OF COMMON PLEAS OF
CUMBElU,ANI> COUNTY, PENNSYLVANIA
v
NO.lJ5.CJI12 CIVIl. TERM
ROBERT J HOOVER, JR,
Delcndant
PIUlTH'T10N FROM ABUSE
MOTION FOR CONTINUANCE
The plaintill~ Linda Ann Orris, by and through her attorney, Joan Carey of Lcgal Services.
Inc" moves the Court for an Ordcr continuinggcncrally thc healing in thc above-captioned case
on the grounds that:
\. A Temporary Protection Order was issued by Ihis Court on Novcmber 24, 1997,
scheduling a hearing for Thursday, December 4, 1997, at 1000 am
2, Cumberland County Sherit1's Deputy, David Zcigler, served the delcndant's
counsel, Gail C. Calderwood, Certified I.egal Intern, of the FAMILY LAW CLINIC with a
certified copy of thc Tcmporary Protection Order and Petition Ihr Protection Order on November
25, 1997, at 4:25 pm, at the Cumbcrland County Shcrin's Ollicc, Cumberland County
Courthouse, Carlisle, Pennsylvania
3, The parties, by and thrnugh their attorneys, agrec that thc hearing scheduled for
Thursday, Deccmber 4, 1997, at 10.00 ft m he continued gcncrally to negotiate an agrccment in
the mattcr.
4, Thc plaintil1' rcqucsts thai Ihc Templllnry protcctiun Ordcr rcmain in ell'cct until
lurther Ordcr of Court,
5, A ccrtilicd copy of thc Ordcr Illl' ContilllllulCC will hc dclivcred to thc New
Cumberland I'olice ()ep"rtmcnt by the attorney thr thc plllintill'
WIIEREFORE, thc plnintit1' rC1lucsts thai thc ('UlIIt grllnt this Motinn IInd continue this
.~ (" I::
(:
i.:~ .. "
Ill' l.:.-,J
f ,-
I"
'-' .. ~ .
Ii'
<'"
(~,: I
L~! r j
- , " 1;.:_
I ..:.
i'.. r- ,.1
l.~:: G~ U
,
I
;
LINDA ANN ORRIS,
Plaintifi'
: IN TIlE COURT OF COMMON PLEAS OF
v.
CUMBERLAND COUNTY,PENNSYLVANIA
NO. 95-lJ 112 CIVIL TERM
ROBERT J. 1I00VER, JR,
Dclcndant
PROTECTION FROM ABUSE
ORDER OF COURT
..
AND NOW, this ~_ day of December, 1997, upon consideration of the attached
Praccipe to Wilhdraw Action tiled in the above-captioned matter, the Temporary Protection
Order entered November 24, 1997. is vacated,
By the Court, )
~t-,Ald- .
Kevin, A. Bess, Judge
Joan Carey
LEGAl, SERVICES, INC.
Attorney for 1'laintilT
,
_ C_fU.oL.
nl~''''L..t. 1:J.j" j,'1.
..s',"1I~
Gail (' Calderwood, Certllled Legal Intern
TholllRS M. l'lace, Attorney at Law
..-.\MIU' LAW U,INIC
Attorney lor I>elcndant
II) . ..
,.. c~
I' ..
I"~ ::;.
I'; ,
,
c.
, .',1
, I
i '-
I' i~
'-'
, I-- I
G' ,~)