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Home My WebLink About96-02199 " " I, .,.... ~ , , 'I . ~ I 1'- !I . ~ " ..,r'- , _..I~..,- " The Cumberland County Sheriff's Department shall attempt to make service at the plaintiff's 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 l by mail. The appropriate Police Departments in the areas where the plaintiff lives and works s~all be provided with certified copies of this Order by the plaintiff's attorney. This Order shall be enforced by any law enforcement agency where a 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 sBction, the defendant shall be taken without unnecessary delay before the court that issued the order. When that court is unavailable, the defendant shall be taken before the appropriate district justice. (23 Pa. C.S. !l 6113). . . J By the' Cou ~. / I ~I UJ ,// -.----.--.JIu ,'.. U-Judg-e--- J I r I: r, ~ l ,I I, l. LINDA MILBOURNE-ROBINSON, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 96-JI'lf CIVIL TERM PROTECTION FROM ABUSE v. WILLIAM L. ROBINSON, Defendant P~TITION FOR PROTBCTION ORDBR RBLIBF UNDBR THE PROTBCTION FROM ABUSR ACT, 23 P.S. ~ 6101 et seq. A. ABUSE 1. The plaintiff, LINDA MILBOURNE-ROBINSON, is an adult individual residing at an undisclosed location. 2. The plaintiff is temporarily staying at an undisclosed location for her own protection and to avoid further abuse as is more fully set forth herein. This address will be furnished to the court upon request. 3. The defendant, WILLIAM L. ROBINSON, SSN:349-42-2518 and 00B:5/9/48, Ls an adult individual residing at 821 Handy Lane, Camp Hill, Cumberland County, Pennsylvania, 17011. 4. The defendant is the husband of the plaintiff. 5. Since approximately November 1994, the defenda,nt ha. ',,' ',j', , attempted to cause and has lntentionally, knowingly, or, recklessly caused bodily lnJury and serious bodily plaintiff, placed the plaintiff in reasonable fear of serious bodily injury, and has knowingly engaged in a conduct or repeatedly committed circumstances which have placed the plaintiff in , " -' of bodily injury. This has included, but is not limited to, the fOllowing specific instances of abuse: a. On or about Aprj.l 1.4, 1996, the defendant backed the plaintiff up against a window and punched her in the face approximately two times with his flst, once in the nose, tho other in the cheek. The defendant then threatoned the plaintIff saying, "If you think you are going to the pollce about this, r will murder you one way or another," and 'iga in h l t her in the mouth. The defendant next grabbed her face between his hands and . squeezed with enough force to cut the plaintiff's face. When the plalntiff tried to walk away, the defendant followed her and punched her in the mouth, causing the I ,I plaintiff pain. The defendant told the plaintiff that he would continue to do t~is to her whenever she was , , late. Whenever she was able to get away, the defendant followed her into the kitchen and grabbed her by the lJ " ar.ms. The next day, when the plaintiff told the \". , the doors for fear of abuse. The defendant came out 'i~' i,!: if J " ( \j ',:~.l defendant that she had filed her taxes, he became extreme I y angry, caus ing her to run to her car and lock after the plaintiff, demanded that she roll down the car window, and tried to force the door handle of the car open. Fe.ning for her safety, the plaintiff drove flom the l''''"id'Hlce. The plaintiff received medical tre.tment including x-rays of her face from Chamber~ I l , Hill Family Practice. b. On or about April 6, 1996, the defendant chased the plaintiff around an Island in their kitchen, caught her, and forcefully grabbed heL by the arms. c. In or around March 1996, the dnfendant became angry because the plalntiff was late in getting home, grabbed her by the arms, and shoved hAr onto the couch telling her that she needed to call him if she was going to be late and forcing her to show him the receipts from the places she had stopped. d. Since the plaintiff's honeymoon in November 1994, the defendant has physically abused the plaintiff in ways including, but not limited to, the fallowing: punChing, kicking, shoving, and Slapping the plaintiff. The plaintiff had a protection from abuse Order against the defendant through Dauphln County in 1994. On at least one occasion, the defendant was found in indirect criminal contempt. 5. On or about Aprll 15, 1996, the plaintiff left her residence at 821 Mandy Lane, Camp Hill, Cumberland County, Pennsylvania, in order to avoid further abuse. 6. The plalntiff b~lieves and therefore avers that .he ia in immediate and present danger of abuse from the defendant, and that she is in need of protection from such abuse. 7. The plaintiff desires that the defendant be prohibited from, having any direct or indirect contact with the plaIntiff including, but not limited to, telephone and written commun lCIl t ions. 8. The plaintiff desires that the defendant be enjoined from harassing and stalking the plaintiff, and from harassing the plaintiff's relatives. 9. The plaintiff desires that the defendant be restrained from entering her place of employment. 10. The plaintiff deslres that the defendant be enjoined from removing, damagIng, destroying or selling any property owned by the plaintiff. ~'_ ,I:!X,CLUSIVE POSSESSI9N 11. The plaintil'f cannot reveal the names of the owners/renters of the home because the names will disclose her whereabouts which must be kept confidential for her protection. The plaintiff is not seeking the eVIction of the defendant from his residence. C. _ "ATTORNEY FEES 12. The plaintiff asks that the defendant be ordered to pay reasonable attorney fees to Legal Services, Inc. WHEREFORE, pursuant to the provisions of the "Protection from Abuse Act" of October 7, 1976, 23 P.S. 6 6101li I.f.g., as amended, the plaintiff prays this Honorable Court to grant the fallowing relief: I , I I I A. Grant a Temporary Order pursuant to the I " 1. Ordering the defendant to refrain from I I "Protect ion from Abuse Act:" , abusing the plaintlff or from placing her in fear of abuse; 2. Orderlng the defendant to refrain from having any dir~ct or indirect contact with the plaintiff including, but not limited to, telephone and \ written communications; 3. Ordering the defendant to refrain from harassing and stalking the plaintiff and from harassing th~ plaintiff's relatives; 4. Prohibiting the defendant from entering the plaintiff's place of employment; 5. PrOhibiting the defendant from removing, damaging, destroying or selling property owned by the plaintiff; 6. .Ordering the defendant to stay away from any residence the plaintiff has now or may establish for herself in the future. B. Schedule a hearing in accordance with the provisions of the "Protection from Abuse Act," and, after such hear ing, ental' an order to be in .ff.ct for' a period of one year: I; . 'i..', 'II'; t The plaintiff prays for such other relief as may be just and proper. Respectfully submitted, ') J;~~-6~i-e~~':/ -" 'Attorney for Pla~ritiff LEGAL SERVICES, INC. a ,Irvine Row Carlisle, PA 17013 (717) 243-9400 " , .' ',' I" Ii' ;',1 1\'1'" , . I" , ., " I"" " " , '11,1 I' ',,:, ,'J \1,'_ I'" ", ,I-> 'I The above-named plaintiff, Linda Milbourne-Robinson, verifies that the statements made in the above Petition are true and correct. 'The plaintiff understands that false statements herein are made subject to the penalties of 18 Pa. C.S. ~4904 relating to unsworn falsification to authorities. \UI~\a' Date: .f', \ ~; .--___.___. ____.._ ,,__,_ o. .u_ tf/.'t~J, )v(If~(lttt(, foCu~cv' r; inda r-il1bourne'::R'obTiisoni -Plalntiff-- , , "', ,'" ": , ' J' , , 1',1 , ' I,tt J,i , , ,', , , , , 'I I: 1\. I) I':, I, '. n " ~ 'r .') " ) " 'j t;'. , II '" :-" I: , C;&; i.1 . . I ~ f , i 8 ~ I. " , \, . " :/ I, :' continuan~e be entered and that pending further Order of Court the Temporary Protection Order remain in effect. Respectfully submitted, (~~~.:"L~_____ At t orney fo~ PI a(,:,'~~-;f LEGAL SERV ICES, I NC. 8 Irvine Row Carl isle, Pe 17013 (717) 243-9400 .. I '. " Ii! 'I I ',~ j. " " '-",!! !,!1il ,t' ;: ~ ' ~ ~ ! I. ! I ". ... 'Li. , II ~ i I 1'111 !l;j ,. !!',,"i1i i.'li ., i"j .[1 T ,".J ,I r-l 'tlIL'f..! lil1 \. I, '1': II ,. I. . III , : ',\'11 " " , II ,. 1." " " , d "N, lJl, . . i'); .' ;, " , 1 j', I, " , , 1 I' I' , , , il'[ , I ,'I " \ 1 i ,', , (' L\! , , " I' 1 ~ I ,I it'; '" , i\ t',JI \,' ,\, 'ill..l: )1' , II ': , " " I.. Ii 1,1. II, 1 , 1 ,~ ! " /"'\'11\ ',1"'1 I' ;\ 1\ II rr' '1,';1' '" f-"ill' I ," ,. I L r'l'li I,ll 1"',11 j ~ I, I.' I,",'" i\ ~ 1 I I ! 11 !. j,.j ~ ; ',; l_!; ! pi :'ITI '1':1 ,'Ii j. )..It!'1 , J'_ll' ., 1',1:\_" ,\ I I, h,,,! I I ~ i j i ,I I IJi [,il,'!1 jl ti ',d'I".. .ofl' jli '-'["'( 1\, .-','__1 I fl'l -I': '11, II 1,;1' i,'I,', 'I, 'f' J ~ ___-P"/ ,,: ), r~~'-~~ , . / ,'" / -; ...", I I , -/ c:/'/ '-'/- ~~'-:-J ,1,1-, :\1,\ 1,;1,'; 1') '" , " iI ~, " I' .}l AA- ~ ?v Ch~ ,a. ht.. ~~,v,~ (OLlC \ ",I, ;"" HFARING DATE: May 6, 19,96 . C · d.' .1., The CQurt CT C.:mmo~ Fla:s or :.J:-.~::::.:;C'l:n .....:;w';;.:y, ?anr:syl'lcni: ~ , Linda M'i Ibourne - Rob inson 'is. William L. RobLnaon :-fo. 96-2199 C Lvi 1 ---. :?- ::iow, April 24 :9~ !. S~~~ 0::-' C~[3:::='''!''A.'f!) CO~;'{~YI :.~ co h=::r, ci...~c::: = :=-= oi Dauphin Cwu::r :0 :..":::".::: =.:s ',v:!:, ":':4 c...::u:=== ::!:11 -~..:. u :!:.:: ~::::t =ci :-=.:.k oi == ?''':-:::. ~.v""~'~4~::.. . . $1e.~ at C:.::::er..:<i C~u:rr, ::1. ASc!a.vit Or Se:-n~ :-iow, ~9 .. o'.:!c= ',(. 1::",":': -. :.::= ~t!:i:: ".1?CZI ~; by ::u:c.=.; :0 A ~ oi =A o::r~"1 ... :IJ:1d -~..:. Caw!: :Jl ::: . . ":=:::=:1 :.-:::::t. So :=we:. SWCr.l ::Ie! 1lICsc::'".l:d == ==:::.is_a1al r_-..-.. -- '\ " COMMONWt:AI:l'lI 01' PI':NNA: COUNTY OF DAlJI'IIIN: , SIIt:IlIFF'S Itl-:TlIRN NO. 96-2199 PAlil-: 416 ANI> NOW: May 1, IU96 .111 3115 P :\1. SEHVEP'I'III'; WlTllIN " Temporary' Protection Order, UI'ON William L. Robinson lIANl>INGTO William L. Robinson B\' PEIlSO~ALJ.Y A TUllE ATTESTED COI'Y OF TilE OIlWINAI. Temporary Protection Order AND MAKINO KNOWN TO him TilE CONTENTS TII'EREOF AT DAuphin County Courthouse, Front & Market St" Harrisburg, Pa RH sp '~~.S\fflAL SHERIFF OF DAUPHIN COUNTY, PCNNA IIY ./J_ - - f) d '"')ft:l ' -,,~/'j /.4) DEPUTY SllEIl 'I' Sworn nnd flubscrib"d tr> before m~' this 2nd_~byofMay 1996 PIWTlION01' AUY SlIfo:UIFt"S emiT ~ N/A S IA