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NOV .1 G /995
IN THE COURT OF COMMON PLEAS OF -F.....
CUMBERLAND COUNTY. PENNSYLVANIA
CIVIL ACTION-LAW
IN PROTECTION FROM ABUSE/CUSTODY
JO ANN I. HOLLOW A Y.
Plaintiff
V.
RAYMOND G. HOLLOWAY. JR..
Defendant
NO. 95-/.,S'~b CIVIL TERM
TEMPORARY PROTECTIVE ORDER
AND NOW, this 1(,. 'fI.day of November, 1995. upon presentation and consideration of
the within Petition, and upon finding that plaintiff. Jo Ann I. Holloway. residing at 4605
Deimler Lane. Enola, Cumberland County, Pennsylvania, is in immediate and present danger
of abuse from defendant, Raymond G. Holloway. Jr., the following Temporary Order is entered.
Defendant. Raymond G. Holloway, Jr., (SSN: 163-60-1416)(DOB: 10/16/65) is hereby
enjoined from abusing plaintiff. Jo Ann I. Holloway, or placing her in fear of abuse. either
personally or through his agents.
Defendant, Raymond G. Holloway. Jr., is hereby enjoined from entering onto plaintiffs
residence at 4605 Deimler Lane. Enola. Cumberland County, Pennsylvania.
Defendant's presence on plaintiffs property shall be restricted to her driveway for the
sole purpose of picking up or delivering their children.
The defendant is enjoined from harassing, threatening, or attacking. either verbally or
physically, the plaintiff or plaintiffs relatives and friends.
The defendant is enjoined from yelling at or screaming at or bad-mouthing the plaintiff
at any time. especially in the presence of their children.
The defendant is enjoined from following or spying on the plaintiff.
.
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The defendant is enjoined from having any telephone contact with the plaintiff except for
the sole purpose of discussion of their children.
The defendant is ordered to rcfrain from having any direct or indirect contact with the
plaintiff including. but not limited to. telephone and written communications. except as
specifically provided for in the preceding paragraph.
A violation of the Order may subject the defendant to: i) arrest under 23 Pa.C.S.
A6113; ii) a private criminal complaint under 23 Pa.C.S. A6113.1; iii) a charge of indirect
criminal contempt under 23 Pa.C.S. ~6114. 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. A6114.1. Resumption of
co-residence on the part of the plaintiff and defendant shall not nullify the provisions of the court
order,
Temporary custody of Bradley P. Holloway, Michael T. Holloway. Andrew R.
Holloway, and Anthony E. Holloway. is hereby awarded to plaintiff. Jo Ann I. Holloway.
Plaintiff shall pennit defendant to have visitation at such times and places as she alone
may detennine.
A hearing shall be held in this mailer on the .,11JItday of November. 1995 at ::!i!fM.,
in Courtroom No. s: Cumberland County Courthouse. Carlisle, Pennsylvania.
The Hampden Township Police Department shall be provided with a certified copy of this
Order by the plaintiffs attorney. 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 presence
of the police officer. In the event that an arrest is made. under this section. the defendant shall
be taken without necessary delay before the court that issued the order. When that court is
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JO ANN I. HOUOWA Y,
Pllindff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: CIVIL AcrION - LAW
: IN PROTECTION FROM ABUSE
RAYMOND G. HOUOWAY, JR.,
DeleIldInt
: 'Is - '5/,04.
: NO. 95- CIVIL TERM
NOTICE
You have been aued in court. If you wbh to defend qalnlt the claimalet forth in the
foIIowiD& pIpI, you mull tab don promptly after thiJ Petidon, Order and Notice ue Ierved,
by IppCIUina penlIIlII1y or by attorney at the hcarin& lChedulcd by the Court and preIelllina to
the Court your cIefea-. or objectiona to the claim. let forth qalnlt you. You ue wamod that
if you fall to do III the Court may proceed without you and a judament may be entered IpinIt
you by the Court, without further notic:c, for any money claimed in the Petition or for any other
claim or relief requated by the Plalndff. You may loae money or p.operty or other rlahll
imponIIIt to you.
RIi'Ji AND COSTS
If the cue aoel to hcarina and thejudae aranlla ProIecdon Order, a aun:har&e of$25.oo
wiD be .,-aed apInat you. You may allO be required to..y aItomcy feel to the Family Law
ClinIc for ill.. T -1atIon of the plalndff.
YOU SHOULD TAKE nus PAPER TO YOUR LAWYER AT ONCE. IF YOU DO
Nor HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE
OFFICE SET FORm BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Court Adminl.trator, Fourth Floor
Cumberland County CourthouJC
Carlialc, Pennlylvania 17013
717/2~2oo
AMERICANS WITII DISABWTIES ACT OF 1990
The Court of Common Plcu of Cumberland County II required by law to comply with
the AmeriCll\l with DiIlbUltica Act of 1990. For informadon about I'Ulllblc flcllitica and
JaIOlIIblc ICCOmmodalionl avallable to dlllbled Indlviduall having bualncu before the court,
plcuc contact our office. AU arranlemenll must be made at 1eaat 72 hours prior to any hearilll
or buaineu before the court. You must attend the scheduled conference or hcarilll.
.
a. On September 24. 1995. the defendant grabbed the plalntiffand threw her several
feet. slamming her body Into a car, causing the plaintiff to receive several external and internal
bruises. The defendant brought the plaintiff to the hospital for her injuries. However, the
defendant forced the plaintiff to leave before the doctor completed the examination. The
hospital. suspecting abuse, notified the police.
b. On September 28. 1995, the plaintiff made the decision to seek a divorce from
the defendant. She informed the defendant of her decision. and since that date. the violence and
abuse has increased.
c. On October 14. 1995, the defendant shoved the plaintiff. causing her to fall over
an embankment and into a field face down. When the plaintiff got up. the defendant grabbed
her purse and bag and threw them into the field. The defendant then yanked the plaintiffs
glasses off her face and threw them also Into the field. causing them to break. The plaintiffs
brother called the police and reported the incident.
d. On October 19, 1995. although the defendant informed the plaintiff that he was
moving out of the house. he also told the plaintiff that the children were the only things keeping
her "fucking alive". The defendant then began destroying furniture and the plaintiff was so
frightened that she felt compelled to leave the house to avoid additional physical abuse, The
police went to the house to report the incident.
e. On October 31, 1995, a letter warning defendant not to abuse or harm plaintiff
was mailed to defendant.
f. On November 10. 1995. the defendant broke down the door to plaintiffs house.
6. Plaintiff believes and lherefore alleges that she will be in immediate and present
danger of continuing serious abuse from defendant and that she is In need of protection from
abuse .
.
WHEREFORE. pursuant to the provisions of the "Protection From Abuse Act" 23
Pa.C.S. 16101 et seq.. plaintiff prays this Court to grant the following relief:
A. Grant a Temporary Order pursuant to the "Protection From Abuse Act":
1) Requiring the defendant to refrain from abusing the plaintiff and from
placing the plaintiff in fear of imminent serious bodily injury either personally or through his
agents;
2) Granting exclusive possession to the plaintiff of the residence;
3) Prohibiting the defendant from harassing. threatening, or attacking, either
verbally or physically. the plaintiff or plaintiff's relatives and friends;
4) Prohibiting the defendant from yelling at or screaming at or bad-mouthing
the plaintiff at any time and especially in the presence of their children;
S) Prohibiting the defendant from following or spying on plaintiff, and from
having any contact with her except by telephone as specified below;
6) Prohibiting defendant from having any telephone contact with plaintiff
except for the sole purpose of discussion of their children;
7) Prohibiting the defendant from entering onto plaintiffs residence;
8) Restricting defendant's presence on plaintiffs property to her driveway.
and such presence shall be solely for purposes of picking up or delivering their children;
9) Any such other relief as the Court deems appropriate and just.
B. Schedule a hearing in accordance with the provisions of the "Protection From
Abuse Act". and afrer such hearing. enter an order against the defendant. to be in effect for one
year. as follows:
1) Requiring the defendant to refrain from abusing the plaintiff and from
placing the plaintiff in fear of imminent serious bodily injury either personally or through his
agents :
2) Granting exclusive possession to the plaintiff of the residence;
3) Prohibiting the defendant from harassing. threatening, or attacking. either
verbally or physically, the plaintiff or plaintiffs relatives or friends:
4) Prohibiting the defendant from yelling at or screaming at or bad-mouthing
the pl3intiff at any time and especially In the presence of their children;
5) Prohibiting the defendant from following or spying on plaintiff, and from
having any contact with her except by telephone as specified below:
6) Prohibiting defendant from having any telephone contact with plaintiff
except for the sole purpose of discussion of their children;
7) Prohibiting the defendant from entering onto plaintiffs residence;
8) Restricting defendant's presence on plaintiffs property to her driveway.
and such presence shall be solely for purposes of picking up or delivering their children.
COUNT II. CUSTODY
7. The allegations in paragraphs one through six are incorporated herein by
reference .
8. Plaintiff seeks shared legal and primary physical custody of the following children:
NIIK Address Au
Bradley P. Holloway 4605 Deimler Lane, Enola 11 years old
Michael T. Holloway 4605 Deimler Lane. Enola 7 years old
Andrew R. Holloway 4605 Deimler Lane, Enola 6 years old
Anthony E. Holloway 4605 Deimler Lane. Enola 6 years old
During the past five years, the children have resided with their parents at 4605 Deimler
Lane. Eoola, Cumberland County, Pennsylvania 17025.
9. The plaintiff, 10 Ann I. Holloway. is the mother of the children. and she currently
resides with the children at the above address.
10. The defendant, Raymond G. Holloway, is the father of the children. and he
currently resides at an unknown location in Cumberland County.
11. Plaintiff has not participated as a party or witness. or in another capacity. in other
litigation concerning the custody of the children in this or another court.
Plaintiff has no infonnation of a custody proceeding concerning the children pending in
a court of this Commonwealth.
Plaintiff does not know of a person not a party to the proceedings who has physical
custody of the children or claims to have custody or visitation rights with respect to the children.
12. The best interest and pennanent welfare of the children will be served by granting
the relief requested because:
a) Plaintiff has been primary caretaker of the children since their birth;
b) Plaintiff continues to exercise parental duties and enjoys the love and affection of
the children;
c) Plaintiff is willing to accept custody of the children;
d) Plaintiff provides the children with a home with adequate moral. emotional and
physical surroundings as required to meet the children's needs.
15. Each parent whose parental rights to the children have not been tenninated and
the person who has physical custody of the children have been named as parties to this action,
Z .,21 2911 J.6b
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JO ANN I. HOUOWA Y,
Plaintiff
: IN THB COURT OF COMMON PLIlAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
V.
.
.
: CIVIL AcnON-LAW
: IN PROTECTION FROM ABUSE/CUSTODY
RAYMOND G. HOUOWAY, JR.,
DeCeadant
.
.
: NO. 95-6566 CIVIL TERM
PROTECTION AND CUSTODY oanD
PROTll'.cnON nOM ABUSE
AND NOW, lhiI ,1t. day of fcL\\I-', 1~ upon conlideration of the Content
~t of the putleI, the followina Order II entered:
1. 'Ibe defendant, Raymond G. Holloway, Jr., (SSN: 163-60-1416) (DOB:
1(116165) II hereby enjoined from abuaina plaintiff, Jo Ann I. Holloway, or Pllcln& her in fear
of abuae, either penonally or Ihrouah hll qenll.
2. Defendant, Raymond G. Holloway, Jr., II hereby enjoined from enterina OIIto
plaintiff'1 ~ Ii 4605 Deimler Lane, Enola, Cumberland County, Pennaylvanla.
3. Defendant'l praenc:e 011 plalntiff'1 plopcrt)' aI1a11 be ratricted to her driveway
for the aoIe purpoIO of pickina up or delivcrlnllhelr children.
4. 'Ibe c1cfendant il enjoined from lwusinl, threateninl, or IllIUlna, either
verbally or phyaic:ally, the plaintiff or plalntiff'1 relalivea and frienda.
5. 'Ibe defendant il enjoined from ye1l1l11li or acreamin& It or bad-moulhin& the
plaintiff Ii lilY time, eapecIa11y in the pmenc:e of their children.
6. 'Ibe c1cfendant il enjoined from followinl or apyilll 011 the plaintiff.
7. 'Ibe c1crendanlls enjoined from havinllllY telephone c:ontact with the plaintiff
\
acept Cor die IDle purpoIC of dllCuuion of die custody of their children.
S. 'I1Ie defendant II onlcred 10 refrain from havlna lilY direct or Indirect conlll:t with
die plaintiff Inc:lucllna, but not limited 10, telephone and wriucn communications, except u
specifically providod for In die precedIna pullraph.
9. A violation of die Order may subject the c1cfendant 10: I) ureal under 23 h.C.S.
16113; Ii) . priVlle criminal complaint under 23 h.C.S. 16113.1; III) . char&e of InclIrect
criminal contempt under 23 h.C.S. 16114, punishable by ImprilOllment up 10 aIx months and
. fine of SI00.QO.SI,OOO.OO; and Iv) civil contempt under 23 h.C.S. 16114.1. Resumption of
~raldence on die part of die plaintiff and c1cfendant shal1 not nullify die provislonl of die court
Older.
10. 'I1Ie Hampden Township Police Department shall be provided with . c:atlfIed copy
of thIa Order by die plaIntifrlattomey. 11IIs Order ahall be enforced by lilY law enforcement
IpIICY where . violation occun by ureal for InclIrect criminal contempt without wamnt upon
pnIbIble c:auIe that thIa Order baa been violaled, whether or not die violation 11 committed In
die pm p~!Il! of die police officer. In die event that III ureal Is mIde, under thll aec:tlon, the
defaldant ahall be 1abn without ~.."Y delay before die court that luued die order. When
that court II unavailable, the defendant shall be taken before the appropriate district jUltice. (23
P.S. 16113).
II. Thil ProtectIon Order ahall remain In effect for. period of one (1) year and CIIl be
ex.,...,wl beyond that time If the Court finds that the c1cfendant baa committed III let of abuse
or baa enpaed in . pattern or practice that lndic:aleJ risk of harm 10 die plaintiff. 'Ibe defendant
undentanda that thll Order will be enforceable in the same manner u the Court'I prior
Temporary Protec:tion Order entered in this cue.
CUSTODY
12. The plaintiff, hereinafter referred to u Mother, ahall have primary pIIylicll
CIIIlOdy ofBndlcy P. Holloway, Michad T. HoJloway, Andrew R. HoJloway, and Anthony E.
Holloway, and the putIea Ihall have joint 1epI custody.
13. The defendant, hereinafter referred to u Father, IhaII have putIal pIIylical
CIIIlOdy of the children OIl the fo1IowIna IItcrnatina week cycle:
.. Durina the fint week, the Father Iha11 pick up the children at Mother'.
raIdence OIl Saturday ..5:00 p.m. and Iha11 have CUItody until Monday momIna when Father
Iha11 taD the children to ICbooI.
b. Durin& the aecond week, the Father Iha11 pick up tile chl1clren at Mother'.
m~ OIl Friday at 4:00 p.m. and Iha11 return tile children to Mother'. raIdence OIl Saturday
.. 5:00 p.m.
14.
PIrtieI aaree to the foJlowina holiday achedule:
.. For the Christmu holiday, Mother Iha11 have CIIIlOdy from Saturday,
December 23, 1995 at 5:00 p.m. until Sunday, December 24, 1995 at 4:00 p.m. Father Iha11
pick up children ..4:00 p.m. and return them OIl Tuelday, December 26, 1995 at 4:00 p.m.
b. The Mother and Father shall, by mutual llreement, mab proviaion. for
IIwina periodI of custody for tile remainlnl holiday..
15. Father shall have such additional periods of partial physical custody at such tlma
u tile Mother qrees.
16. ni. Custody Order IhaIl remain In effect until either party petitions to have It
c:han&ed.
17.
The mother and father 11m: that each shall notify the other of III medical care
:~
JO ANN I. HOu.oWAY,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL AcrJON-LA W
IN PROI'ECIlON FROM ABUSBlCUSTODY
V.
RAYMOND G. HOu..oWAY, JR.,
Defendant
NO. 95-6566
CIVIL TERM
CONSENT AGR~DmNT
'Ibia Apeement 11 cntenld OIl thia r:y of ~..fk-r995, by the plaintiff, Jo Ann
I. Holloway, Ind the defendant, Raymond G. Holloway, Jr. The plaintiff ia rqh mnled by The
Family Law CIiJIic. The defendant ia repa lleRled by Bdwud W. Harker, Eaqun. The putica
.. tbat the foUowina may be cntenld u an Order of Court.
I. The defendant, Raymond G. Holloway, Jr., (SSN: 163-60-1416) (DOS:
10(16165), aI""""" cntaina into thia Apeemcnt, cIoca not Idmit the an,.tlona made in the
Petition.
2. The clcfcndant, Raymond G. HOlloway, Jr., aareea to refrain from ablllina the
plaintiff, Jo Ann I. Holloway, or Pilcin& her in fear of abuac.
3. The clcfcndant qreea not to have any direct or indirect conllct with the plaintiff
includina, but not limlled to, telephone and written c:ommunicationa, except for the limiled
pIIJpOIC of facilitatiq CUIIOdy UI'IIIIClnCftta.
4. The clcfcndant aareea not to Iwua, threaten, or atllIck, either verbIlly or
phyaically, the plaintiff or plaintiff'a relatives and menell.
5. The defendant qreea not to yell at or Ic:ream at or bid-mouth the plaintiff at any
time, ...,eclally in the presence of their childral.
6. The defendant qreea not to follow or spy on the plaintiff.
'.
7. The defendant IIRCI not to have any tc1cphonc contKt with the plaindff acept
for the IOIe purpoIC of dilcuuion of the custody of their children.
S. The defendant qreea to refrain from havlna lilY direct or Indirect contKt with
the plalndff includina. but not limited to. telephone and written communication., acept u
IpOCifically provided for in the Prec:edin& parqraph.
9. The defendant IIRCI to atay away from the plaindfrs raidcnce IocIIted 1&4605
Deimler LIIIe, IlIlola, Cumberland County, Pennsylvania, except for the limited purpoIC of
trIIIIfarina c:uatody.
10. The defendant undcntands 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 Coull finda
that the defendant baa committed III IICl of ablllC or baa cnpaed in a pattem or pnctk:e that
i'ld~- riIk of harm to the plaindff. The defendant \IIIdcrataIIdI that this Order will be
enfORlelble in the 11IM manner u the Court's prior Temporary P......tion Order entered in thiI
C&Ie.
11. A violation of the Protecdon Order may IUbject the defendant to: I) arrat under
23 hC.S. 16113; li) a private criminal complaint under 23 PI.C.S. 16113.1; ill) a cJwae of
indiJect criminal contempt under 23 PI.C.S. 16114, punishable by ImprilOllmcnt up to Iix
monthl and a fine of 5100.00-51,000.00; and iv) civil contempt under 23 PI.C.S. 1611U.
Raumption of co-realdcnce on the put of the plaintiff and defendant Ihall not nullify the
proviIionI of the court order.
12. The defendant and plaindff IIInlC to the entry of a Custody Order providina for
the followina c:uatody schedule for their children, Bradley P. Holloway, Michlel T. Holloway,
Andrew R. Holloway, and Anthony E. Holloway. The defendant, hereinafter referred to u
Father, shall have partial physical custody of the children on the followina altematin& week
cycle:
.. Durina the ftnt week, the Father Iha1I pick up the children at Mother'.
reaIdence OIl Saturday at 5:00 p.m. and Iha1I have custDdy until Monday momina when Father
IhaIlIIb the c:hiIdren to 1choo1.
b. Durina the IeCOIId week, the Father IhaII pick up the cItI1dren at Mother'.
reaIdence OIl Friday at 4:00 p.m. and IhaII return the children to Mother'. raldence OIl Saturday
at 5:00 p.m.
13. Putla IpIlC to the followina holiday lChedu1e:
.. For the Chrlltmll holiday, Mother IhaII have custody from Saturday,
nr-'- 23, 1995 at 5:00 p.m. until Sunday, December 24, 1995 at 4:00 p.m. Father IhaII
pick up children at 4:00 p.m. and return them OIl Tuelday, December 26, 1995 at 4:00 p.m.
b. Tbe Mother and Father 1haII, by mutual qreement, mike proviIloIlI for
IIharina periodI of CIIItody for the rernalnina holiday..
14. Father Iha11 have IUCh IddltiorW periodl of putiIl phylica1 CIIItody at IUCh tima
u the Mother 1p'CCI.
15. Tbe putla IpIlC that the CllllOdy Order IhaII mnaln in effect until either pIlty
petitloaa to have it c:han&ed.
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JO UII J:. D.IIILD,
plaintiff
IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
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v.
: CIVIL ACTION - "LAW
: IN CUSTODY
..YXOIID G. HOLLOWAY,
Defendant
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: NO. 95-6566 CIVIL TERM
AGR...IIT TO KODIry CUSTODY
UD JOIIIT KOTIO. rOR .IITRY or AGR.1III1DlT U ORDD or COURT
THIS AGREEMENT, lIade thh
/8 ~h day of December, 1997,
between plaintiff, Jo Ann Deilller, hereinatter mother, and
defendant, Raymond Holloway, hereinafter father, concerns the
custody of the children: Bradley Holloway, born 8/22/84, Michael
Holloway, born 12/14/87, Andrew Holloway, born 4/16/89 and Anthony
Holloway, born 4/16/89.
Mother and father desire to enter into an agreement as to the
shared custody of the children during the lIajor holidays of
Christllas, Easter and Thanksgiving. Additionally, both parties wish
to enter into an agreement regarding custody of the children on the
dates of each party's respective remarriage. Mother and Father
request that this agreement be made an Order of Court. Therefore,
each party agrees to the following:
1. Mother shall have physical custody of the children by
6:00 pm on Decellber 24, 1997 and will return them to Father by
12:00 noon on December 25, 1997.
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2. Mother and Father shall alternate yeare during which each
party has physical custody of the children on Christmas morning so
that Mother has the children on Christmas morning in odd numbered
years, and Father shall have the children on Christmas morning in
even numbered years.
3. Mother will have physical custody ot' the children tor
Easter in 1998 and will have custody of the children on Easter in
tuture even numbered years.
4. Father will have physical custody ot the children tor
Easter in 1999 and will have custody ot the children on Easter in
tuture odd numbered years.
5. Father will have physical custody ot the children tor
Thanksgiving in 1998 and will have custody ot the children on
Thanksgiving in future even numbered years.
6. Mother will have physical custody ot the children tor
Thanksgiving in 1999 and will have custody ot the children on
Thanksgiving in tuture odd numbered years.
7. Mother shall have custody ot the children during the
weekend ot June 13, 1998 so that they may attend her wedding.
8. Father shall have custody ot the children during the
waekend of July 4, 1998 so that they may attend his wedding.
9. The parties intend to be legally bound by the terms of this
I agreement and agree that it shall be made on Order of Court.
-~ /( 4t.ed. ....I~ 1:J-lh'-97
ad G." Holloway.('
Defendant
,J.,-IJ- 97
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