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MARLENE E. DUFF,
Plaint! ff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY. PENNSYLVANIA
v.
NO. 95- 1,.9'1'"
CIVIL TERM
RALPH L. DUFF, JR.,
Defendant
: PROTECTION FROM ABUSE AND CUSTODY
TEMPORARY PROTECTION ORDER
11
AND NOW, this _ (, day of December, 1995, upon presentation and consideration of
the within Petition, and upon finding that the plaintiff, Marlene E. Duff, temporarily residing
at an undisclosed location for her own protection and to avoid further abuse, is in immediate and
present danger of abuse from the defendant, Ralph L. Duff, Jr., the fo\1owing Temporary Order
is entered. Law enforcement agencies, human service agencies and school districts sha\1 not
disclose the presence of the plaintiff and/or the children in the jurisdiction or district or furnish
any address, telephone number, or any other demographic information about the plaintiff and/or
children except by further Order of Court,
The defendant, RalIih L, Duff, Jr" (SSN: 042-32-4792)(008: 12/30/40), now residing
at 3 Smith Road, Gardners, Cumberland County, Penn~ylvania, is hereby enjoined from
physically abusing the plaintiff, Marlene E. Duff, or placing her in fear of abuse.
The defendant is excluded from the marital residence located at 3 Smith Road, Gardners,
Cumberland County, Pennsylvania, a residence which is jointly owned by the parties, and is
ordered to stay away from any residence the plaintiff may in the future establish for herself.
The defendant is ordered to refrain from having any direct or indirect contact with the
plaintiff or the plalntifrs minor children Including, but not limited to, telephone and written
communications.
The defendant is enjoined from harassing and stalking the plaintiff and from harassing
her relatives, or the minor children.
The defendant is enjoined from entering the plalntifrs place of employment or the
schools of the plaintifrs minor children or the day care facility of the minor children.
The defendant is enjoined from removing, damaging, destroying or selling any property
owned jointly by the parties or owned by the plaintiff.
A violation of this Order may subject the defendant to: I) arrest under 23 Pa.C.S.
16113; 11) a privste criminal complaint under 23 Pa.C.S. 16113.1; III) a charae of Indirect
criminal contempt under 23 Pa.C.S. 16114, punishable by imprisonment up to six months
and a nne of $100.00-$1,000.00; and Iv) civil contempt under 23 Pa.C.S. 16114.1.
Resumption of co-residence on the part of the plaintiff and defendant shall not nullify the
provisions of the court ol'der.
This Order shall remain in effect until modified or terminated by the Court and can be
extended beyond its original expiration date if the Court finds that the defendant has committed
an act of abuse or has engaged in a pattern or practice that indicates risk of harm to the plaintiff.
Temporary custody of Jennifer L. Duff and Garrett S, Duff, is hereby awarded to the
plaintiff, Marlene E. Duff,
I (~
A hearing shall be held 011 this matter on the .J:l day of December, 1995, at
/Dt!l:m., In Courtroom No.-.:. Cumberland County Courthouse. Carlisle, Pennsylvania.
The plaintiff may proceed without pre-payment of fees pending a further order after the
hearing.
The Cumberland County Sheriffs Department shall attempt to make service at the
plaintiffs request and without pre-payment of fees, but service may be accomplished under any
applicable rule of Civil procedure.
This Order shall be docketed in the office of the Prothonotary and forwarded to the
Sheriff for service. The Prothonotary shall not send a copy of this Order to the defendant by
mail.
The Pennsylvania State Police and any other appropriate police department shall be
provided with certified copies of thi~ 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 pre~nce of the police officer, In the event that an aRest is
made, under this section, the defendant shall be taken without unnecessary delay before the court
that issued the order. When that court is unavailable, the defendant shall be laken before the
appropriate district justice. (23 P.S. ~ 6113).
Judge
Joan Carey
LEGAL SERVICES, INC. ' (~J>uJ ,1./('1,. JJ/'~"/J,ltt /J.(/ 1{
Attorney for Plaintiff I I / (,
MARLENE E. DUFF,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL TERM
NO.9S-
RALPH L. DUFF, JR.,
Defendant
: PROTECTION FROM ABUSE AND CUSTODY
NOTICE
You have been sued in court. If you wish to defend against the claims set forth in the
following paaes, you must take action promptly after this Petitioll, Order and Notice are served,
by appearing personally or by allomey at the hearing scheduled by the Court and presenting to
the Court your defenses or objections to the claims set forth against you. You are warned that
if you fail to do so the Court may proceed without you. and a judgment may be entered against
you by the Court without further notice for any money claimed in the Petition or for any other
claim or relief reqlJested by the plaintiff, You may lose money or property or other rights
important to you.
FEES AND COSTS
If the case goes to hearing and the judge grants a Protection Order, a surcharge of $2S.00
will be assessed against you, You may also be required to pay allorney fees to Legal Services,
Inc. for their representation of the plaintiff,
You should take this paper to your lawyer at once. If you do not have a lawyer or
cannot afford one, go to or telephone the office set forth below to nnd out where you can
get lepl help.
COURT ADMINISTRATOR, 4th FLOOR
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PENNSYLVANIA 17013
TELEPHONE NUMBER: (717) 240-6200
AMERICANS WITH DISABILITIES ACT OF 1990
The Court of Common Pleas of Cumberland County is required by law to comply with
the Americans with Disabilities Act of 1990, For information about accessible facilities and
reasonable accommodations available to disabled individuals having business before the court,
please contact our office. All arrangements must be m:ade at least 72 hours prior to any hearing
or business before the court.
MARLBNB B. DUFF,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Y.
NO. 95- ,,9'/1c.
CIVIL TERM
RALPH L. DUFF, JR.,
Defendant
: PROTECTION FROM ABUSE AND CUSTODY
PETITION FOR PROTECTION ORDER
AND CUSTODY
RELIEF UNDER THE PROTECTION f'ROM ABUSE
ACT, 13 P.S. . 6101 et seq.
A. ABUSE
1. The plaintiff, Marlene E. Duff, is an adult individual temporarily staying at an
undisclosed location for her own protection and to avoid further abuse as is more fully set forth
herein. This address will be furnished to the court upon request,
2. The defendant, Ralph L. Duff, Jr.. (SSN: 042-32-4792)(DOB: 12/30/40), is an
adult Individual residing at 3 Smith Road, Gardners, Cumberland County. Pennsylvania, 17324.
3. The defendant is the husband of the plaintiff.
4. Since approximately 1993, the defendant has attempted to cause and has
intentionally, knowingly, or recklessly caused bodily injury to the plaintiff, ha~ placed the
plaintiff in reasonable fear of imminent serious bodily injury, and has knowingly engaged in a
course of conduct or repeatedly committed acts toward the plaintiff, under circumstances which
have placed the plaintiff In reasonable fear of bodily injury. This has Included. but is not limited
to, the fol1owlng specific instances of abuse:
a) On or about November 29, 1995, the defendant charged toward the
plaintiff with his fists clenched at his sides, pushed against her with his chest,
crabbed her b) the throat with both his hands, pushed her backward over the
kitchen sink and choked her. The defendant released the plaintiff when the
plaintifrs daughter and her boyfriend came into the kitchen after hearlna her
scream, Fearing further abuse, the plaintiff dialed 911 for assistance. The
defendant snatched the telephone from her hand and jerked the telephone cord out
of the receiver, but not before the call was dispatched to the Pennsylvania Slate
Police. When the plaintiff told the defendant she was leaving because of his
abusive behavior, he threatened her saying, "You're lucky that's alii did to you."
The plaintiff sustained soreness about her neck as a result of this Incident. The
plaintiff and her four children left the home and have been Slaying at an
undisclosed location since this incident for their protection and to avoid further
abuse,
b) On or about November 4, 1995, the defendant went to the residence where
the plaintiff and her children had gone the day before to avoid abuse and
threatened her saying, "If you fuck with me. I just might have to kill YOII,"
causing the plaintiff to fear for her safety.
c) In or about July of 1995, the defendant threatened to kill himself with one
of his guns.
d) On or about April 16, 1995, the defendant became angry, slammed the car
doors and punched the side of the car, The plaintiff, who was inside the car with
her children, feared for their safety.
e) Since approximately 1993, the defendant has abused the plaintiff in ways
Including, but not limited to, pushing her about with his chest, grabbing her by
the arms, Intimidating the plaintiff and the children by pulling his list back IU if
to strike the plaintiff or the children, slamming his lists on the table, throwing
household objects, and punchi~g walls. In addition, the defendant, who was an
explosives expert in the military, has made threats to the plaintiff including, but
not limited to, telling her that with his knowledge he could easily wire a car to
explode when the door opens or a toilet seat to explode when sat upon, causing
the plaintiff to fear for her gafety and that of her children.
S. On or about November 29, 1995, the plaintiff and the four minor children left
their residence at 3 Smith Road, Gardners, Cumberland County, Pennsylvania, in order to avoid
further abuse.
6. The plaintiff believes and therefore avers that she is in immediate and present
danger of abuse from the defendant should she return to the home without the defendant's
exclusion and that she is in net:<! of protection from such abuse,
7. The plaintiff desires that the defendant be prohibited from having any direct or
indirect conlaCt with the plaintiff including, but not limited to. telephone and written
communications.
8. The plaintiff desires that the defendant be enjoined from harassing and stalking
the plaintiff. and from harassing her relatives, or the minor children.
9. The plaintiff desires that the defendant be restrained from entering her place of
employment or the schools of her minor children or day care facility of the minor children.
10. The plaintiff desires that the defendant be enjoined from removing, damaaing,
destroying or selling any property owned jointly by the parties or owned by the plaintiff.
p.. EXCLUSIVE POSSFSSI~
II. The home from which the plaintiff is asking the Court to exclude the defendant
is owned in the names of Marlene E. Duff and Ralph L. Duff, Jr,
12. The plaintiff currently has no place to stay with her children except the marital
home. The defendant has sufficient income to afford to rent a room or an apartment if he
chooses not to stay with friends in the area.
13. The plaintiff desires possession of the home so as to give the greatest degree of
continuity to the lives of the children and to allow them to continue their education at their
schools and to continue their school and social activities,
14. The plaintiff desires the defendant to provide suitable alternate housing for her and
the minor children.
C. SUPPORT
15. The defendant has a duty to support the plaintiff and the parties' minor children.
16. The plaintiff is in need of financial support from the defendant including, but not
limited to: health insurance coverage, payment of unreimbursed medical expenses for the
plaintiff and the children, the mortgage payment on the residence at 3 Smith Road, Gardners,
Cumberland County, Pennsylvania.
17. The defendant is employed by the Commonwealth of Pennsylvania and receives
an annual salary of approximately $20,000, and in addition, receives monthly checks for
approximately $1,085 ($13,020 annually) in disability payments from the military, and $126
,
;.
(SI,512 I/Inually) in retirement pay from the military. A. total of approximately S34,532
I/Inually.
18. The plaintiffs income is insufficient to provide for her minimal needs and those
of the children until such time: as a support order can be obtained by filing at the Domestic
Relations Office.
19. The plaintiff intends to petition for support within two weeks of the Issuance of
a protective order.
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D. A TIORNEY FEES
20. The plaintiff asks that the defendant be ordered to pay reasonable attorney fees
to Legal Services, Inc.
E. TEMPQRARY CUSTODY
21. The plaintiff seeks temporary custody of the following children:
lSamc
Present Resldegg:
Ale
Jennifer L. Duff
undisclosed location
3 years old
DaB: May 7, 1992
2 years old
DOB: March 25, 1993
Garrett S. Duff
undisclosed location
The children were not born out of wedlock.
The children are presently in the custody of the plaintiff, Marlene E. Duff, who is
temporarily residing at an undisclosed location.
Since their births the children have resided with the following persons and at the
following addresses:
NIall Addr - Dala
Plaintiff undisclosed location November 29, 1995 to present
P1~ntiff, defendant, plaintiffs 3 Smith Road November 10, 1995,
children from previous marriqe, Gardners, PA to November 29, 1995
Nicole Thomas and Jack Thomas
,',' Plaintiff, Nicole Thomas, Jack 406 Raymond Drive November 3, 1995
Thomas, plaintiffs friends, Donna Boiling Springs, PA to November 10, 1995
and Mark Burkhead, and their son, Jason
Plaintiff, defendant, Nicole, 3 Smith Road October 30, 1995
I and Jack Gardners, PA to November 3, 1995
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I. Plaintiff, defendant, Nicole, 316 Forge Road December, 1993
and Jack Boiling Springs, PA to October 30, 1995
Plaintiff, defendant, Nicole, 7113 Sharon Road August, 1992
and Jack Fredericksburg, V ^ to December, 1993
Plaintiff, defendant, Nicole, Bradford Road May 7, 1992
and Jack Wiscasset, ME to August, 1992
The plaintiff, the mother of the children, is Marlene E. Duff, currently residing at an
undisclosed location for her own protection and to avoid further abuse.
She is married.
The plaintiff currently resides with the following persons:
NIIDf
Relatlonsl\lJl
Nicole Thomas
Jack Thomas
Jennifer Duff
Garrell Duff
her daughter
her son
her daughter
her son
The defendant, the father of the children, is Ralph E. Duff, Jr., currently residing at 3
Smith Road, Gardners, Cumberland County, Pennsylvania.
He Is married.
The defendant currently resides alone.
22. The plaintiff has not previously participated In any litigation concernlna custody
of the above mentioned children in this or any other Court.
23. The plaintiff has no knowledge of any custody proceedings concerning these
children pending before a court in this or any other jurisdiction.
24. The plaintiff does not know of any person not a party to this action who has
physical custody of the children or claims to have custody or visitation rights with respect to the
children.
25. The best interest and permanent welfare of the parties' minor children will be met
if custody Is temporarily granted to the plaintiff pending a hearing in this matter for reasons
including:
a. The plaintiff is a responsible parent who can best take care
of the minor children and has provided for the emotional and
physical nwls of the children since their births.
b. The defendant has shown by his abuse of the plaintiff that
he is not an appropriate role model for the minor children.
c. The defendant's behavior has adversely affected the
children.
WHEREFORE, pursuant to the provisions of the "Protection from Abuse Act" of October
7, 1976,23 P.S. 06101 C1 SQ., as amended, the plaintiff prays this Honorable Court to grant
the following relief:
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A.
Orant a Temporary Order pursuant to the "Protection from Abuse Act:"
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Orderlna the defendant to refrain from abusina the plaintiff and/or
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the minor children or placing her in fear of abuse;
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2.
Orderlna the defendant to refrain from having any direct or
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indirect contact with the plaintiff or the plaintiffs minor children
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including, but not limited to, telephone and written communications;
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3.
Ordering the defendant to refrain from hara.,sing and stalking the
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plaintiff and from harassing her relatives and the minor children;
4. Prohibiting the defendant from entering the plaintiffs place of
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employment or the schools of the plaintiff's minor children or the day care
facility of the minor children;
S. Prohibiting the defendant from removing, damaging, destroying or
selling property jointly owned by the parties or owned by the plaintiff;
6. Granting possession of the home located at 3 Smith Road,
Gardners, Cumberland County, Pennsylvania, to the plaintiff to the
exclusion of the defendant pending a final order in this mailer;
7. Ordering the defendant to stay away from the plaintiffs current
residence which is at an undisclosed location for the plaintiffs protection,
which 'he parties have never shared;
8. Ordering the defendant to stay away from any residence the
plaintiff may in the future establish for herself;
9. Ordering the defendant to provide suitable alternate housing for the
plaintiff and the minor children, and
10. Granting temporary custody of the parties' minor children to the
plaintiff.
B. Schedule a hearing in accordance with the provisions of the "Protection from
Abuse Act," and, after such hearing, enter an order to be in effect for a period of one year:
I. Ordering the defendant to refrain from abusing the plaintiff or
placing her in fear of abuse.
2. Ordering the defendant to refrain from having any direct or
indirect contact with the plaintiff including, but not limited to, telephone
and written communications, except to facilitate custody arrangements.
3. Ordering the defendant to refrain from harassing and stalking the
plaintiff and from harassing her relatives and the minor children.
4. Prohibiting the defendant from entering the plaintiff's place of
employment or the schools of the plaintiffs minor children or the day care
facility of the minor children.
5. Prohibiting the defendant from removing, damaging, destroying or
se\ling property jointly owned by the parties or owned by the plaintiff.
6. Gl'anting possession of the home located at 3 Smith Road,
Gardners, Cumberland County. Pennsylvania, to the plaintiff to the
exclusIon of the defendant.
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7. Orderlna the defendant to stay away from any residence the
plaintiff may In the future establish for herself.
8. Orderlna the defendant to provide suitab!~ alternate housing for the
plaintiff and the minor children.
9. Granting support to the plaintiff and the minor childrrn In an
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appropriate amount according to the support guidelines payable to the
plaintiff in the form of a check or money order, malIed to her address,
and ordering the defendant to provide health coverage to the spouse and
minor children, directing the defendant to pay all of the unreimbursed
medical expenses of the plaintiff and minor children of the defendant to
the provider or to the plaintiff when she has paid for the medical treatment
and directing the defendant to make or continue to make rent or mortgage
payments on the residence of the plaintiff,
10. Ordering the defendant to pay reasonable attorney fees Ie Legal
Services, Inc.
The plaintiff further asks that this Petition be filed and served without payment of fees
and costs by the plaintiff, pending a further order at the hearing, and that certified copies of this
Petition and Order be delivered to the Pennsylvania State Police Police Department and any
other appropriate police departments who have jurisdiction to enforce this Order.
The plaintiff prays for such ether relief as may be just and proper.
, ,.d,.___,_
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COUNT II
x
CU$1ODY UNDER PENNSYLVANIA CUSTODY LAW
26. The alleaatlons of Count I above are Incorporated herein as If fully set fonh.
27. The best Interest and permanent welfare of the minor children will be served by
conftrmlna custody In the plaintiff as set forth in Pll1'lIIraph 25 of the Petition.
WHEREFORE, pursuant to 23 P.S. f 5301 ~ JIlQ., and other applicable rules and law,
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the plaintiff prays this Honorable Court to award custody of the millor children to her.
The plaintiff prays for such other relief as may be just and proper.
Respectfully submitted,
(&~/ A~":;;
EGAL SERVICE.~.
8 Irvine Row
Carlisle, PA 17013
(717) 243-9400
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The above-named plaintiff, Marlene E. Duff, verifies that the statements made In the
above Petltlun are true and correct. The plaintiff underslands that false statements herein are .
made subject to the penalties of 18 Pa.C.S. 04904 relatlns to unsworn falsification to authorities.
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MARLENE E. DUFF,
plaintiff
IN THE COURT OF COMMON P~EAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V.
= 95-6976 CIVIL TERM
RALPH L. DUFF, JR.
Defendant
: CHARGE: INDIRECT CRIMINAL CONTEMPT
QBMR OF COURT
AND NOW, this lf~ day of April, 1996, this Court certifies
that the attached complaint has been properly completed and
verified, and there is probable cause for the issuance of
process. In consideration of the attached Commonwealth's
petition, the defendant, RALPH L. DUFF, JR., is directed to
appear for trial on the charge of Indirect Criminal Contempt
before the Court on the 3 tV( day of ~~..............., 1996 at J; 30
o'clock -.a .m. in Courtroom * ;l of theDcumberland County
courthouJe, Carlisle, Pennsylvania.
The defendant has a right to be represented by an attorney.
If the defendant cannot afford an attorney, upon request one will
be assigned to represent the defendant. If the defendant wiohes
assignment of counsel, contact should be made prior to trial with
the Cumberland County Public Defender'o Office at 717-240-6285.
Further, if the defendant fails to appear, an arrest warrant will
be issued.
The Sheriff of Cumberland county is directed to serve this
Order and Petition upon the defendant. The assessment of costs
to be determined by the Trial Judge subsequent to trial.
By t e conrt,
J.
Michael S. Schwoyer L"1'; 11Jt-......f7~.
Chief Deputy Oistrict Attorney ~f~f(f~
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RALPH L. DUFF, JR. - ~-"1" .....~(..t W, ,/..
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MARLENE E. DUFF, IN THE COURT OF COMMON PLEAS OF
pl,intiff CUMBERLAND COUNTY, PENNSYLVANIA
V.
95-6976 CIVIL TERM
RALPH L. DUFF, JR.
Defendant CHARGE: INDIRECT CRIMINAL CONTEMPT
COMMONWEALTH'S PETITION FOR A HEAR~NG ON CHARGES
OF I~DIRECT CRIMINAL CONTEMPT
Michael S. Schwoyer, Chief Deputy District Attorney of
Cumberland County, Pennsylvania brings the following Petition for
a hearing on charges of Indirect criminal Contempt:
I. A Protection from Abuse Order was issued by the Court.
A true and correct copy of the Order is attached.
2. The defendant's violation of this Order is averred in
the attached private criminal complaint.
3. The victim raquests the filing of an Indirect Criminal
Contempt charge upon information received.
4. The District Attorney's Office approves the filing of
this private criminal complaint.
5. The commonwealth is requesting a trial on the charges
of Indirect Criminal Contempt pursuant to 23 Pa.C.S.A. S6113.
6. The plaintiff and the defendant may seek modification
of the Order based on the filing of this petition as the Court
deems appropriate following the trial in addition to any other
sentence. 23 Pa.C.S.A. S6117.
WHEREFORE, the commonwealth requests the defendant be
commanded to appear before the Court on the charge of Indirect
Criminal Contempt.
Attorney
MARLENE E. DUFF,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 95- f.-. Y' 'tit'
CIVIL TERM
RALPH L. DUFF, JR.,
Defendant
PROTECTION fROM ABUSE AND CUSTODY
TEMPORARY PROTECIJQN ORDER
t\
AND NOW, this ~ day of December, 1995, upon pre~ntation and consideration of
the within Petition, and upon finding that the plaintiff, Marlene E. Duff, temporarily residing
at an undisclosed location for her own protection and to avoid further abuse, is in immediate and
present danger of abuse from the defendant, Ralph L. Duff, Jr., the following Temporary Order
is entered, Law enforcement agencies, human service agencies and school districts shall not
disclose the presence of the plaintiff and/or the children in the jurisdiction or district or furnish
any address, telephone number, or any other demographic information about the plaintiff and/or
children except by further Order of Court,
The defendant, Ralph L. Duff, Jr" (SSN: 042-32-4792)(DOB: 12/30/40), now residing
at 3 Smith Road, Gardners, Cumberland County, Penn,~ylvania, is hereby enjoined from
physically abusing the plaintiff, Marlene E, Duff, or placing her in fear of abuse.
The defendant is excluded from the marital residence located at 3 Smith Road, Gardners,
Cumberland County, Pennsylvania, a residence which is jointly owned by the parties, and is
ordered to stay away from any residence the plaintiff may in the future establish for herself.
TRUE COPY FROM RECOfID
In TestIn100y wtMrtlOf, I her., unto ~ my hItld
and ~ ~ 0' :;aid Coor 3t rll~le. PI
I _ lay.. 01 .
The defendant is ordered to refrain from having any direct or indirect contact with the
plaintiff or the plalntifrs minor children including, but not limited to. telephllne and written
communications,
The defendant is enjoined from harassing and stalking the plaintiff and from harassing
her relatives, or the minor children.
The defendant is enjoined from entering the plaintiffs place of employment or the
schools of the plaintifrs minor children or the day care facility of the minor children.
The defendant is enjoined from removing, damaging, destroying or selling any property
owned jointly by the parties or owned by the plaintiff.
A violation or this Order may subject the derendant to: I) arrest under 23 Pa.C.S.
16113; II) a private criminal complaint. under 23 Pa.C.S. 16\13.1; III) a charge or Indirect
criminal contempt under 23 PI.C.S. 16114, punishable by imprisonment up to six months
RDd a fine or $100.00-$1,000.00; aDd Iv) civil contempt under 23 Pa.C.S. 16114.1.
Resumption or co-residence on the part or the plaintiff and derendant shall not nulllry the
pro'Vlslons or the court order.
This Order shall remain in effect until modified or terminated by the Court and can be
extended beyond its original expiration date if the Court finds lhatthe defendant has committed
an act of abuse or has engaged in a pattem or practice that indicates risk of harm to the plaintiff.
Temporary custody of Jennifer L. Duff and Garrell S, Duff. is hereby awarded to the
plaintiff, Marlene E, Duff,
CRIMINAL COMPLAINf
l'OLICIl
ClJlnplallU Numb." ,io;hlr fI,,,u;I,,,,,,.
DISTRICT JUSTICE
MAGIITIRIAL DISTRICT NO.
iiCTDiin NllM'TijO,-L
H2-873349
----.-.------
I. 'rpr. Matthew A. MAXEL..672Q.
(S""'I' ,,/.llIiUMfI
COMMONWEAL TH OF PENNSYL VANIA
111;'-tN()M'll VS
NAM' r.. curF, Ralph I.eqnard Jr: lX8 12/'JIi/.fJJ
AND 75 W1nch..ter GIrdIna
AIHIIH>S Carli'l. PA 17013
SSN 042 32 4792
"SA PH (717) 241-6735
A'A
of I'lLStotILPQlice. Carl,isllil
(MtH"/1" ,1",'II"mr'Kr .J' llN'''' I" "'pr.'wlth',1 ,md (""""'l' whd'l/ll""!
do h~r~hy state:
11 )*~ 1 "('('UM! thl' uhuw naml1d dl'fplHJunl, whu hvtls at tht' uddCt'~!; M't forth (lbOVl' or,
(] 1 Ul'l'Wil' an lIHH\'iduul whOM' nanll' IS unknown to IlW hut who IS dt..'\t'r11wd u:,
"
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[J hiS Illrknnnw or popular dl'SI~ltallo/l I:, unknown to 1111' alld, ttwrt'fort,. I I1I1Vi' dl'Slllllall'd hlln twn'in us .John 1)0l';
with vlllllllllI~ thl'Ill',u.llaws lIf till' t'lIll1ll111I1W.."lth "f 1'1'III1'ylvalllll a' 3 SmIt:h~.=I"h_"lrldl""'~~_
;'7,/,. nl,7Jr:flnr"I"ir~,1f';""-~r~...--------
.
~
III Cumberland ('''''Illy "II "' "!l",,, 04/21/516 19OOhl:'a.------ ".__
PnrlH'lpllllls Wl'rl' 10 III",' '."", 1',jllI! '1'./11/\ "{,j" ,I,,'j' II,HI"\ Ir,'/' I, 1"',III'r~' /'I! 0/,'"'' , ./1"'" ,I. II fI,t,I'I' Ralph Leonard DUFF Jr
(2)
Th., ads "umnllttl.d hy th., ll('('us,,1I wt.weAI Indieect criminal contempt IIIilIliiliD_KItX JC 9174
In that the defendant during a custody exchange of the minor children called the victim
a slut and threw a Bag of EN clothes striking the victim in Nt the head. These actions
constitue harassment and are in violation of PFA 95-6976
Victim: Marlene Elizabeth DUFF
3 Smith Rd
Gardners PA 17324
PH (717) 486-8467
allofwhich w{'rll a ainst ttw J('Ul'I' and dlM"llIly of tilt' ('OlllllHlI\Wl1ulth of Pl'finsylvlIlllu and ('ontrary to tht1 Adof ^ss(lmhly,
or in violation of. 'and of tht' I\d of ____..*.____.._.___.___.~_____..______*__
,Sllll k, //"11
ur th..
.___..___J)rfllllarll'l' ()f .__ ___._'__.__,.___._.__.------~-,.--*.
','/III(<lI,,"",/ILIII')/11
(3)
1 ask that a warrant of arrest 1Olt1liCWlM""-tlml be issued and that the al'cused be required to answer the charges
1 have made,
(4)
I, v~rify that the fa..ts set fu,th in this ..omplaint ar~ tru~ and l'Orr~l't to th~ best of my knowled~e or infor.
mation and belief. This verification is made subj~ct to the p.malties of Se<'tion 490., of th., Crim~s Code
(18 Pa, C,S, 84904) r~lating to unsworn falsification to aut.horities,
-,.--- -.. ..-.. ,- -.- -....04/22-__,. , 1996_
.__~ ~, ~/~=~_u,______
fSIJl"atlJrj~lf A-;'~
AND NOW, on this ,19 ,I ..ertify thlll'omplainl has b~,'n PlOp~r1y l'ompl~l.'d and
v~rj(\ed, and that th~re is p,,,bllbl~ ..atlS" for lh., issuanl'~ of PIO('l'SIi.
(,\'f1Nutl'n{Jllhilnd)
_,____ (SEAL)
(1.i,~Ulrrlll'uOI()r/h)
AOPC '11 .8RPO
IJP 7'OQM (1 t .83)
PENNSYlVANIA ITATI POlICE!
VICTIM/WITNESS STATEMENT FORM
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IN 11lE OOURT OF \nNlN PLEAS OF
P lalnti rr
ClN3ERLAND COIJNTV, PfNNSYLVANIA
NO. 95-6976 CIVIL TERM
PROTECTION FR~ ABUSE AND CUSTODY
v.
RALPH L. DUFF, JR.,
Defendant
Nn'l<>>l POR <DrrINUANCE
The plaintiff lOves the Court for an Order continuing generally the
hearing In the above-captioned case on the grounds that:
I. A Temporary Protection Order was Issued by this Court on December
6, 1995, scheduling a hearing for December 14, 1995, at 11:00 a.m.
2. The CUmberland County sheriff's Department deputized the Dauphin
County Sheriff's Depart~nt and the defendant was served with a certified copy
of the Temporary Protection Order and Petition for Protection order on
Wednesday, December 13, 1995, at approximately 3:30 p.m. at his place of
emp I oYllen t .
3. The defendant's attorney, Samuel L. Andes, requested a continuance
on December 14, 1995, to afford him time to meet with the defendant.
4. The plaintiff agreed to the continuance and requests that the
matter be continued generally pending further Order in this matter.
5. The plaintiff requests that the Temporary Protection Order remain
In effect unt il IIIOdlfied or terminated by the court after not ice or hearing.
6. Cert If ied copies of the Order for Cont \nuance will be de 11 vered to
the Pennsylvania State Pollee and the carlisle Police Depart..nt by the
attorney for the plaint Hf.
, ,
WHEREFORE, the plaintiff requeats that the court Irant this Notion and
continue thia .atter lenerallY, and that the Te.porary Protection Order re.ain
in effect until further Order of Court.
Respectfully sub_itted,
LIIlAL Sl!RVICBS, ItiC.
8 Irvine Row
Carlisle. PA 17013
(717) 243-9400
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COMMONWEALTH OF PENNA I
COUNTY OF DAUPHIN I
SHERIFF'S RETURN
NO. 95-6976
PAGE 142
AND NOW: Dec. 13th
19 95 ,Ill 3:30 P. M.
SERVED 'rilE
.WITHIN Temporary Protection Order ,__~!,otection~{!,.QI1!~buse_.!ll'~~1!'___,_,_,__,__ UPON
Ral{h L. Duff, Jr
HANDING TO Ralph 1. Duff, Jr.
IlY PERSONALI,Y
A TRUE ATTESTED COPY OF THE ORIGINAL
fran abuse order
AND MAKING KNOWN TO
Temproary protection Order Protection
him
THE CONTENTS THEREOF AT Place of
Employment, Capital Complex, East Wing Canplex underground garage, Harrisburg, Pa.
,
Sworn and subscribed to
before me thU ' 12 ayOf.-,Qe'.1:,
01a^'w,u /1'1 . .
r;ROTIIO~;~ /' (1A(//j~)
19
95
SHERlt't.,S COST $ ,Ai /,4
S-lA