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Home My WebLink About96-02758 " , I " I j I ' I I , , I ~ 1 ~ , I ' , ..... .. .~ .. <:J t; ~; ~ ~ ~ 'i ~ ~ " 1 '1 " , ' " " , ' ~ ., ~ .~ ,V) d ,I ,', " " , " ,,, ,I:' " defendant had taken her car without her permission and left. 1'he defendant returned 11 short time I'lter, told the plaintiff that he had also taken the support lOOney her children's father had given hill', and was not going to give it bllck to hill'. When the plllintiff took the money and t!"i(,,1 to run from the house, the defendant grubbed her by the arm, shovlld her down into II chair, leaned close to her fllce, and demanded the money from her. When the plaintiff got away from the defendant, he followed her outside and threatened to beat her. The Pennsylvllnia Stut., Police arrived and issued the defendllnt u c I tat ion for haras8mllnt. The defendant left the residence thut night and has been residing wi th his mother since this Inc [dent. bl On or about May 9, 1996. the defendant grabbed the plaint Iff by her arms, shoved her down onto the couch, straddled her, held her down by her arms demanding her that she I isten when he spoke to her, and threatened that he would tear her home apart. c) On or llbout May 2. 1996, the defendant slapped the plaintiff on the side of her hel\d as she held her 5 year old son, Joshua, in her arms. d) In or about early March. 1996, the defendant put his face up to the plaintiff's face, yell(,d at her, grabbed her by the neck while holding a I it cigarette in his fingers, and squeezed her neck causing her neck to be burned by th,~ cigarette. 5. The plaintiff believes and theref'll'e avers thllt she is in i_diate IlrId present danger of ahuse from the defendant, should she relll81n in the tx.e 2 without the defendant '5 exc1ullion and Hun she is in need of protect ion from such IIbuse. 6. The plaint iff desirell that thl' defendant be prohibi ted from having IIny direct or indirect contllct with the plaintiff or the plalntiff'll minor children including, but not I imi ted to, telephone nnd writ ten communicat ions. 7. The plaintiff dellires thllt the defendunt he enjoined from harussing and stalking the plaint iff, und from hnraslling her relnt ivus, or her minor chIldren. R. The plaintiff dellires that the defendant be restrained from entering her place of employment or school. 'l. The plaintiff desirell that the defendant be enjoined from removing, dal1lliging, destroying or selling any property owned jointly by the parties or owned by the pili inti ff. >>.. EXCLUS IVE POSSESS.J.Qtj 10. The apartment from which the plllintiff is IIsking the Court to exclude the defendllnt is rented in the name of Mel issl'\ .J. Seiders. The defendant IIOved out on May 10, 1996, and has been residing ut 50 Gordon Drive', Carlisle, since then. G,,--REIMB!!RSM:NT FOR ~T 01' CASE 11. The plaintiff askll thut the dcfendunt he ordered to pay $200.00 to one of l.egnl Services, Inc. 'Il funding sourcell for the cost of I il.igating this case. ~IEREF()RE, pursuant to the provillions of the "Protection '"1'011I Abuse Act" of October 7, 1976, 231'.5. 6 6101 ~1 ;-;'119., liS umended, the plaintiff prays this Honorable Court to grant the follOWing relief: 3 A. Orant a TemporRry Order pUrllultll1 to the "Protect Ion frll. Abuse Act:" t. Ordering the dcfendunt 10 refmln from Rbusina the plaintiff or plucing her In fear of abuse; '2. Ordering the defendant to refrain from having /in:,' direct or indirect contact with the plRintiff or the plaintiff's minor children including, but not limited to, telephone and written cOlMlunicat ions; J. Ordering the defendanl to refrain from harassing and stalking the plaintiff and from harassing her relatives and her minor chi Idreni 4. Prohibiting the defendant from entering the plaintiff's place of employment or business or schlX)l; 5. Prohibiting the defendRnt from rClIOving, d/lM8ing, destroying or sell ing property joint Iy owned by the parties or owned by the plRlntiff; 6. Ordering the defendRnt to stay away from the plaintiff's residence locRted /l.t 7 Pine Roud, Apt. 602, Mt. Holly Sprllll,9, Cumberland County, Pennsy!vRnia, pending R final order In this mat tel', and 7. Ordering the defendllnt to stRY Rway from any residence the pi/lint Iff may in the fulure establ ish for herself. D. Schedule R hearing in accord.~nce with the provisions of the "Protect Ion from Abuse Act," and, after such hearing, enter Rn order to be in effect for II period of one YCllr: 4 I. ' Ordering the defendllnt to refrain from ahus ing the pllllnt Iff 01' placing her in fellr of Ilbuse. 2. Ordering the defendant to refrAin from having any direct or indirect contact with the plaintiff or the plllintlff's minor chi Jdrcn including, but not I imi tcd to, tclephone and written communications. J. Ordering the defcndant to refrain from harassing and Iltalking the plaint iff and from harassing her rclat ives and her minor children. 4. Prohibiting the defendant from entering the plaintiff's place of employment or husiness. 5. Prohibiting the defendant from removing, damaging, dest.roying 01' sell ing property joint Iy owned by the part ies or owned by the plaintiff. 6. Ordering the defendant to stay away from the plaintiff's residence located at 7 Pine Road, Apt. 602, Mt. Holly Springs, Cumberland County, Pennsylvania. 7. Ordering the defendllnt to stay away from any residence the plaintiff may in the future establish for herself. 8. Ordering the (Icfcndant to pnY$200.00 to one of Legal Services, Inc. 's funding sources for the cost of litigating this cllse. The plaintiff further IIsks thnt this Petition be filed and served without payment of fees and costs by the plllint iff, pending a further order at the 5 , , . I , il , , i , , ,', " , i , 1\ I', :,: I, , ! 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