HomeMy WebLinkAbout96-02855
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DORIAN KAY OEE,
IN Tlffi COURT OF C~ PLFAS OF
Plliint iff
CUMBERLAND COUNTY. PENNSYLVANIA
v,
NO, 96- J ~.,.,
CIVIL TERN
JOHN CLARENCE PETERSON, II I ,
Defendant
PROTEC'TION FROM ABUSE
PBTITION fQIU~'lU11'tX:T10N ORDER
RELIEF UNDER 11IE PRm'ECTION f1QI ABlJSE
AL~, 23 Pa.C.S, 16101 et aeq,
At-NlU--5E
1, The plaintiff, Dorian Kay Gee, is an adult individual residing at
Salem Acres Mobile Home Park, 6280 Car I isle Pike, Lot 411, Mechanicsburg,
Cumberland county, Penr.sylvanla 17055.
2. The defendant, John Clarence Peterson, III, (SSN: 160-60-7422)
(008: 5/28/72), is an adult individual residing at 1353 Vernon Street,
Harrisburg, Dauphin County, Pennsylvania, 17104.
3. The defendant has had an intimate relationship with the plaintiff.
4. Since approximately March, 1994, the defendant has attempted to cause
and has intentionally, knowingly, or recklessly caused bodily injury to the
plaintiff, has 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 plaint i rr including following the plaint iff wi thout proper
authorization, under circumstances which have placed the plaintiff in reasonable
fear of bodi Iy injury, This has included, but is not 1 illli ted to, the fOllowing
specific instances of abuse:
a) On or about May 5, 1996, the defendant entered the plaint Iff's
residence and refused to leave despite the plaintiff's requests thnt
he do 80.
FCflfing for her safety, the plaintiff went to a
nuighbor's home and telephoned the pol ice. When the plaintHf
returned to her home, thu defendant who was still there, followed
her to her bedroom, and blocked the doorway keeping her in the
bedroom for approximately IS minutes, The Hampden Township Police
arrived and advised the defendant to leave.
b) On or about April 30, 19Q6, as the plaintiff walked to her
home from her place of tomploYllent she noticed the defendant's
sister's pickup truck with two men inside had pulled up behind her
and turned the lights off. When she was safe inside her home, the
plaintiff saw the same pickup truck had moved and was parked on the
street a short distance froll her home, Fearing she was being
stalked by the defendant, the plaintiff telephoned the police. The
truck was not there when the police arrived. The defendant later
admit ted to the plaint iff that he was in the truck that night
watching her.
c) On or about April 30, 1996, the defendant tried to kick in the
plaintiff's door, and when he was unsuccessful in gaining entry, he
broke a window. Fearing for her safety, the plaintiff telephoned
the police, The police escorted the defendant froll the home.
d) On or about Apri I 27, 1996, the defendant C8llll to the
plaintiff's home, and when she tried to te,lephone the police, the
defendant ripped the telephone cord from the wall and slapped the
telephone from her hand. The defendant then picked the plaintiff up
by her waist and carried her to the bedroom. The plaintiff got away
frolD the defendant and called out the window for help, but he
2
grabbed her by the hai r, dragged her away froll the window. threw her
onto the bell, pulled her off of the bed by her feet when she would
not stop screaming, and covered her mouth with his hands to quiet
her. The defendant allowed the plJlintiff to get up, but followed
her to the kitchen, pinned her against the counter, shut a drawer
agl\inst her hand, slapped a cup out of her hand and a cigarette out
of her mouth as she sat on a chair, followed her about the living
room, and shoved her down into a chair threatening to get violent
wi th her if he had to make her listen to him. The
plaintiff telephoned the police. The plaintiff sustained bruises on
both her elbows as a result of this incident.
el In or about early March, 1996, the defendant straddled the
plaintiff as she sat on the bed, threatened to kill her, and choked
her with such force that she lost consciousness. When the plaintiff
regained consciousness, the defendllnt st ill had his hands on her
throllt, The plllint!ff sustained soreness aLJut her neck as a result
of this incident,
f) In or about mid-October, 1995, the defendant flipped the
glass-topped coffee table over, threw a can of beer in the direction
of the plllintiff's 18 month-old daughter, and pushed the plaintiff
down onto the bed.
gl In or about the fall of 1994, the defendant slapped a
cigarette out of the plaintiff's mouth, t~)k her glasses off of her
face and kept them knowing that she cannot see without them, grabbed
her by the hai l' and her neck, led her to her cllr and forced her into
J
the car, The defendant strapped the seat belt on the plaintiff,
hvld his hand over the seat belt release so she could not get out,
and forced her tQ drive a distance without her glasses. When they
got back to the defendant's apartment, he shoved the plaintiff onto
the bed and refused to let her It:lIve the bedroom for several hours.
h) In or about May, 1994, the def.!lIdant IIhoved the plaintiff down
onto the couch and threatened to throw out of the window of the
three story apartment they lived in.
i) In or about March. 1994, the defendant pushed and shoved the
plaint i ff about and he Id a kni fe against her throat,
S, The plaintiff believes and theTefore avers that she Is In IlIIIIediate
and present danger of abuse from the defendant should she remain in the home
without the defendant's exclusion and that she is in need of protect Ion frOll such
abuse.
6. The plaintiff desires that the defendant be prohibited frOll having
any direct or indirect contact with the plaintiff or her nlinor child inclUding,
but not limited to, telephone and written communications,
7, The plaint i rr des i res that the defendant be enjoined frOtll harassing
and stalking the plaintiff, and from harassing her relatives.
8. The plaint Iff desires that the defendant be restrained froll entering
her place of employment or school.
9. The plaintiff desires that the defendant be enjoined from re80ving,
d8118ging, destroying or sell ing any property owned joint ly by the part ies or
owned by the plaintiff.
4
IL.- EXtWllrntJ:'QWi1lMl1:ti
10, The mobile home from which the pllllntiff Is a~king the C;ourt to
exclude the defendant is owned In the names of Dorilln Kay Gee lInd John Clarence
Peterson, III. The defendant moved out of the home in or about early April,
1996, and has been re~iding with his mother, I.avondll Peter~on, at 1353 Vernon
Street In Harrisburg, Pennsylvania,
11. The plllint iff current Iy has no place to stay with her chi Id except
the mobile home, Ilnd the defendant has fllmi Iy and friends in the area with whom
he can stay.
12, The plaintiff desires possession of the home so as to give the
greatest degree of cont inul ty to the I I fe of the chi Id,
!,:. RllIMllURSf1t4EN'I' fi)R COST Of CASE
13. The plaintiff asks that the defendant be ordered to pay $250.00 to
reimburse one of Leglll Services, Inc. 's funding sources for the cost of
litigating this case.
'MIERllFORE, pursuant to the provisions of the "Protect Ion from Abuse Act"
of October 7. 1976, 23 P.S. 86101 et seQ., as IiJJlended, the plaintiff prays this
Honorable Court to grant the following rei ief:
A. Grant a Temporary Order pursuant to the "Protect ion from Abuse
Act:"
I. Ordering the defendant to refrain frolD abusing the
plaint Iff or placing her in fear of abusej
2. Ordering the defendllnt to refrain from having any direct
or indirect contact with the pln!ntiff or her minor child
5
inciuding, but not limited to, teiephone and written
cOlllllunicat ion~1
3, Ordering the defendant to refrain from harossing and
stalking the plaintiff and from hal'lllllling her relatives;
4, Prohibit ing the defend,~nt from entering the plaintiff's
place of employment or school;
5, Prohi!!i t ing the defendant from relllOving, dalllaging,
destroying or sell ing property ,joint Iy owned by the parties or
owned by the plaintiff;
6. Grant ing posses~ion of the IIIObi Ie hOllle located at Salem
Acres Mobile Home Park, 6280 Carlisle Pike, Lot 411,
Mechanicsburg, Cumberland County, Pennsylvania, to the
plaintiff to the exclusion of the defendant pending a final
order in this mat tel', and the defendant is ordered to stay
away from any other residence the plaintiff MY establish for
herse 1 f.
8, 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 peri~l 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 or her minor child
including, hut not limited to, telephone and written
cOllUllun Icat ions.
6
J, ,Ordering the defendant to refrain froll haralllllng and
stalking the II 1I1intIff IlI1d from harallslng hur relatives,
4, Prohibiting the dufcndant from entering the plaintlff'll
place of umployment or /lchool,
5, Prohlbi t ing the defendant from rellllVlng, dlUllllg I nil ,
delltroying or /lelllng property joint Iy owned by the parties or
owned by the plaintiff,
6, Granting pollsession of thu mobile hoMe located at Salem
Acres Mobile Homu Park, 6280 Carlisle Pike, Lot 411,
CUllberland County, Pennsylvania, to the plaintiff to the
exdullion of the defendant, and ordering the defendant to Iltay
away from any residence the plaintiff may In the future
establish for herself.
7, Ordering the defendant to pay $250.00 to reimburse one
of Legal Services, Inc. 'II funding sources for the cost of
litigating this case.
The plaintiff further asks thllt this Petition be filed and served without
paYJllent of fees and costs by the plaint iff, pending a further order at the
hearing, and that Il certified copy of this Petition and Order be delivered to the
Hampden Township Police Department which has jurisdiction to enforce this Order.
The plsintlff prays for such other relief as may be just and proper.
Rl!llpectfU~1 sUbm,lt ted,
) , ----
...-1-. if ve(_
oan Carey, Attor for Plaintiff
LtxlAL SERVIC.f.8, I ..
8 Irvine Row
Carlisle, PA t7013
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OORIAN KAY GEE,
IN WE (:OURT OF COMMON Pl.EAS OF
Plaint i ff
CUMBERl.AND COUNTY, PENNSYI.VANIA
v.
NO, 96-2855 CIVIL TERM
JOlIN Cl.ARF.NCE PETERSON, III,
llefendant
PR<YrECTlON FROM ABUSE
PR01'EC'[.L~ ORDER , , I
AND NOW, this _:>.i~:l day of __~'IJI "1 ,lc)c)6, upon consideration ,of th,
Consent Agreement of the part les, the following Order Is entered:
1. The defendant, John Clarence Peterson, III, is enjoined from
physically abusing the plaintiff, o..~rinn Kay Gee, or from plncing her in fear of
nhllse.
2. The defendant is enjoined from hnving nny direct or indirect contact
with the plaintiff including, but not limited to, telephone /lnd written
commun i ca t ions.
.1. The defendant is ordered to refrain from harassing and stalking the
plaintiff and from hnrnsslng her relat Ives nncl her minor chi Id.
4, The def.mdant Is prohihj ted from entering the plnint iff's place of
employment nnd school,
5. The defendnnt is prohlhlted from removing. damaging, destroying or
sell,ing any property owned hy the plaintiff or jointly o'Nned hy the parties,
6. The defendant is excluded frolll the pla,intiff's residence located at
Salem Acres Mohile lIome Pnrk, 62RO Cnrlisle Pike, l.ot 411, Meclumicshurg,
Cumberland County, Pennsylvanin, nnd the defendant is ordered to stay away from
nny residence the plnint I ff may in the future estnhllsh for herself.
7. Court costs find fees IHe wlliverl.
7, The defendllnt, IIltho'lgh entering into this Agreement, does not IIdmit
the IIllegat Ions made in the Pet i lion,
8. The defendant understnnds that tht;' Protect ion Order entered in this
mat ter wi II be In effect for a per ioll of onll (I) yellr anrl can be extended beyond
that time if the Court finds thllt the defenc\ant hilS committed an act of abuse or
hilS engaged in n pat tllrn or prnct iCIl thllt Ind i cntes r !sk of hnrm to the
plaint iff, The defendant uncll'rstands thnt this Order wi II be enforceable in the
same manner as the Court's prior TemporllrY Protection Order entered In this case,
,
9. Violnt ion of the Protllct ion Order may subjllct the defendant to: i)
arrest under 23 Pa.C.S, 9h1Ll; i I) a privntll criminal complaint under 23 Pa.C,S,
96113.1; iii) a charge of indirect criminal contempt under 23 Pa.C.S. 96114,
punishnble by imprisonmllnt up to six months nnd II fine of $100,00-$1,000,00; and
iv) civil contempt under 23 Pn.C.S. 96114.1.
\\1IEREFORE, the part ies rllquest thnt II Protect ion Order be entered to
reflect the above terms.
~~..lA-
Dorian Kay Ge~ Plaintiff
.'--1: IJ(0~~
J6 Carey, Attorney ,ryr Plaint iff
1.HlAJ, SERVICES, INC:.
8 Irvine Row
Carlisle, PA 17013
(717) 243-9400
=.0>
olin Clarence Peterson. 11.1, Defendant
OORIANKAY GEE,
IN mE COURT OF cot.MlN PLF.AS OF
CUMBERLAND COUNTY, PENNSYLVANlo:\
NO, 96-2855 CIVIL TERM
PROTECTION FROM ABUSE
Plaint Iff
v.
JOHN CLARENCE PETERSON, III,
Defendant
AND NOW,
tf:., ORDER
this 7-(" day of June, 1996, upon consideration of the within
Petition, the portions of the Protection Order, dllted May 31, 1996, which
prohibited the defendant, John Clarence Peterson, III, from having any direct or
indirect contact with the plaintiff, Dorian Kay r~e, Including but nDt limited
to, telephone and written communicl\tions, l\nd excluded the defendant from the
plaintiff's residence lit Salem Acres Mobile Home Park, 6280 Carlisle Pike, Lot
411, Mechanicsburg, Cumberland County, Pennsylvania, or l\ny other residence she
ma)' in the future establish for herscl fare vllcated.
In all other respects the Protection Order entered May 31, 1996, remains
in effect,
By the Court,
J.
Joan Carey
LmAL SERVICES, INC,
Attorney for Plaintiff
Ci,'''fi fUL-U)W'lu '}<-I.'..t..... 'lu/'"
---, M......
John Clarence Petersont III J 1
Defendant U,71 )"I1..'fr.( 6/~/'if6..
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DORIAN KAY GEE,
PlaintilT
IN TIlE COURT OF COMMON PLEAS
CUMBERl.AND COUNTY, PENNSYLVANIA
v,
NO. <)6.2855 CIVIL TERM
JOHN CLARENCE PETERSON, III,
Defendant
PROTECTION FROM ABUSE ANI> CUSTODY
TEMPORARV PROTECTION ORDER
AND NOW, this _L1~ay of June. 1998. upon presentation and consideration of the
within Petition, and upon linding that the plaint ill Dorian Kay Gee, now residing at Salem Acres
Mobile Home Park, 6280 Carlisle Pike. l.ot 411, Cumberland County, Pennsylvania, is in
immediate and present danger of abuse from the delendant, John Clarence Peterson, III, the
",\lowing Temporary Order is entered
The defendant, John Clarence Peterson, III (SSN 160-60-7422) (DOB: 5/28/72), an adult
~ndividuaJ residing or:l~hitehall Street, Harrisburg, Dauphin County, Pennsylvania, is hereby
enjoined from physically abusing the plaintiff, Dorian Kay Gee, or from placing her in fear of
abuse,
The delendant is excluded from the plaintilfs residence located at Salem Acres Mobile
Home Park, Lot 411, Mechanicsburg, Cumberland County, Pennsylvania, a residence which is
jointly owned by the plaintilT and delendant, and is ordered to stay away Irom any other residence
the plaintiff may establish for herself The delendant vacated the plaintill's residence in late
November 1997, and has since resided with his mother in Harrisburg,
The defendant is ordered to refrain Irom having any direct or indirect contact with the
plaintift' including, but not limited to, telephone. written, third party, or electronic
communications,
The delendant is enjoined Irom harassing and stalking the plaintift. and Irom harassinll her
relatives,
The defendant is enjoined from entering the plaintill's place of employment or the day care
facility of the parties' minor child
The defendant is enjoined Irom damaging or destroying any property owned jointly by the
parties or owned solely by the plaintill:
A violation of this Order may subject the defendant to i) arrest under 23 Pa,C.S, ~6113;
ii) a private criminal complaint under 23 l'a,C.S, ~6113,1; 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 l'a('S ~61141 Resumption of co-
,
residence on the part of the plaintill' and delendant shall not nullitY the provisions of the court
order,
This Order shall remain in ellect until modified or terminated by the Court and can be
extended beyond its original expiration date if the Court finds that the delendant has committed an
act of abuse or has engaged in a pattern or practice that indicates risk of harm to the plaintiff,
l,...t'vIGI, ,"u;uud,. uf die Pilllles d.lld, Andua, J",..r.lm:' Pi-I..... o.TVlI. :~ h~reh} 8nftrtlod to
.hl plaiRtiW, Q9AaA Kay gSI.
The defendant is ordered to relinquish to the sherill's d~partment~ny weapons which he
...""~",\'U,, . t.l,JI, .)"'041'
, ,,/,~ns or Plse~ses, including, but not limited to a shotgun, ~used or t ri!atened to use in an
Ct incident oJAatts~against the plaintilT. The defendant is prohibited from acquiring or possessing
any other weapons for the duration of the Order and is required to relinquish to the sheriff any
firearm license the defendant may possess, The delendant' s weapons and firearm license may be
returned at the expiration of the Protection Order after the defendant has submitted a written
request to the Court for the return of the weapons and the Court has notified the plainlilf of the
request and given the plaintiff an opportunity to respond A copy of this Order shall be
transmitted to the chiefor head of the police department of the Pennsylvania State Police (Carlisle
Barracks), and any other appropriate police departments,
'.... .
A IIEARING SIIAl.l, BE IIELD ON THIS MATTER ON TIlE ~
DA YOI' JllNE, 1998, AT .3: 00 f .M., IN (:OlJRTROOM NO. I
01' TIn: UJMBERI.AND COlJNTY COlJRTlIOlJS..:, CARUSI,E,
PENNSYI,VANIA.
The plaintit}. may proceed without pre-payment of Ices pending a further order after the
hearing
The Cumberland County Sherin's Department shall anempt to make service at the
plaintin's request and without pre-payment of Ices, but service may be accomplished under any
applicable rule of Civil Procedure,
This Order shall be docketed in the ofiice of the Prothonotary and lorwarded to the Sheriff
for service The Prothonotary shall not send a copy of this Order to the defendant by mail,
The Hampden Township Police Department shall be provided with a certified copy of this
Order by the plaintiffs anorney, This Ordcr 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, whcther or not the violation is commined in the presence
of the police otl1cer, 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
unavailable, the defendant shall be taken bcfore the appropriate district justice, (23 Pa,C.S,
~6113)
DJ'~"2l~L l .
o U- ~
Joan Carey
LEGAL SERVICES. INC.
Anomey for Plaintiff
I CII/~" J
7'I,otl<-
"
1. I S
a) On or about June 14, 1998, the defendant telephoned the plaintitrs
residencr;: and lell a threatening message on her answering machine saying,
"Paybacks are a bitchl"
b) On or about June 9, 1998, the delimdant lell a message on the
plaintill's answering machinc yclling, "You want to play games'll Now it's
time tor John to play games, you luckin' bitch, no good whore, You'd
belieI' watch your step outside the luckin' h\luse Go ahead and call the
cops and get me tor harassment . cause I'll be over there in a tUckin'
heartbeat." The plaintill'leared for her satety
c) On or about May 29, J 998, the detendant contronted the plaintitl'
outside her residence. argued with her, and when she threatened to call the
police, he lell, Since this date the detendant has repeatedly telephoned the
plaintitrs residence, as oil en as 12 times in a day, despite beingtoJd by her
not to call, During his telephone calls to the plaintitf, the detendant has
harassed her, called her names, hung up repeatedly, and lell threatening
messages on her answering machine, causing her to tear tor her safety,
d) On or about May 22, 1998, the defendant went to the plaintitrs
residence, approached her in an agressive manner, screamed at her while
jabbing his finger in her facc, walked away, turned back toward her, and
screamed, "Fuck you'" and a barrage of other obscenities, The plaintifl'
told the detendantto leave or she would call the police,
e) On or about May 2 J, 1998. the delendant went to the plaintifl's
residence, followed her into her residence uninvitcd, refused to leave,
grabbed her breasts and genital area, and when she tried to push him away,
he backed her against the wall, pinned her with his body. and kissed and
Ibndled her despite pleas lor him to stop, After the plaintiff got away from
the defendant, he lollowed her, pinned her against the wall in the hallway,
and backed her against the kitchen counter. holding the counter with his
hands on each side of her, preventing her Irom leaving, The delendant
linally len the plaintitl's residence aller several hours of her telling him to
leave, Shortly aileI' this incident the plaintill' began to have significant and
potentially dangerous mechanical problems with her vehicle, Her mechanic
checked the vehicle and advised her that the lug nuts on both front wheels
ofthe vehicle were so loose that the wheel was about to come ofT the axel,
and the power steering pump had heen tampered with, The plaintilT
suspected that the defendant had damaged her vehicle and reported it to the
Hampden Township Police,
t) In or about May 1998. the defendant told the pla.intilT during a
telephone conversation that he possessed a shotgun,
g) On or about December 9, 1997. Legal Services, Inc, stalT sent the
defendant a warning letter (see Exhibit A incorporated herein by relerence)
at his residence by certilied and regular mail. bo:h of which were returned
to the offices of Legal Services, Inc, marked by the post office,
"Attempted, Not Known," The same letter was again mailed on January
12, 1998, by certified and regular mail addressed to the defendant at his
place of employment. The certified letter was returned to the offices of
Legal Services, Inc, marked by the post (lllice. "Unclaimed," but the copy
of the letter sent by regular mail was not returned, From early December
1997, to early January 1998. the defendant wrote several letters to the
plaintilfand wedged at least one letter in the jamb of her door,
h) In or about late November 1997, the defendant argued with the
plaintiff and drew his fist back twice in a threatening manner, causing the
plaintitl'to feai he was going to hit her
i) On or about November 23, 1997, the defendant argued with the
plaintiff, followed her to her triend' s house, entered the house uninvited in
pursuit of the plaintitf, and left after the friend told him to get out.
j) On or about September 14, 1997, the defendant became angry, up-
ended the cotl'ee table, narrowly missing the plaintiffs 4-year-old daughter,
The plaintiff left the residence, telephoned the Uampden Township Police
for help, returned to the residence with the police. and retrieved her child
from the detendant. After leaving her child with the babysitter, the plaintiff
drove to her place of employment. The defendant, who had followed her,
pulled alongside the plaintilrs vehicle, demanded that she roll down her
window, and when she did not, he became angry and punched the driver's
window, Fearing for her safety. the plaintiff drove back to her residence
with the defendant driving right behind her vehicle, Because she was afraid
to leave her vehicle, she drove through the mobile home park repeatedly
while honking the horn and shouting for someone to call the police to help
her, After this incident, the plaintiff and her children left the residence and
did not return until late October 1997.
\
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k) On or about May 22, 1996, the plaintiff tiled a Petition for
Protection Order against the defendant, and a Temporary Protection Order
was entered to the above-captioned docket, The parties entered into a
Consent Agreement and a Protection Order was entered on May 31, 1996,
See Exhibit B incorporated herein by reference,
5, The plaintiff believes and therefore avers that she is in immediate and present
danger of abuse from the delendant should she remain in the home without the delendant's
exclusion and that she is in need of protection from such abuse,
6. The plaintill' desires that the delendant be prohibited from having any direc\ or
indirect contact with he~ including, but not limited to, telephone, wrillen, third party or electronic
communications,
7, The plaintiff desires lhatlhe delendant be enjoined Ii-om harassing and stalking the
plaintiff, and from harassing her relatives,
8, The plaintill'desires that the defendant be restrained from going to her place of
employment or the day care facility oflhe parties' minor child,
9, The plaintiff desires that the defendant be enjoined from damaging or destroying
any property owned jointly by the parties or owned by the plaintiff,
B. EXCLUSIVE POSSESSION
10, The mobile home located at Salem Acres Mobile Home Park, 6280 Carlisle Pike,
Lot 411, Mechanicsburg, Cumberland County, Pennsylvania, Ii-om which the plaintiff is asking the
Court to exclude the delendant, is owned in the names of Dorian Kay Gee and John Clarence
Peterson, "' The defendant moved out of the home on or about November 28, 1997, and has
been residing with his mother, Lavonda Peterson, on Whitehall Street in Harrisburg, Pennsylvania,
II, The plaintiff currently has no place to stay with her minor children except the
mobile home,
12, The plaintiff desires possession of the home so as to give the greatest degree of
continuity to the lives of the children,
C. REIMBURSEMENT FOR COST OF CASE
11 The plaintiff asks that the defendant be ordered to pay $250,00 to Cumberland
County, one of Legal Services, Inc,'s funding sources, as reimbursement lor the cost of litigating
&m
Plaintiff. Morgan, defendant's
sister and brother-in-law, Bonnie
and Bob Parthemore, their children,
Brillany, Tristan, Summer, Peyton, Bobby, Jr, and inlimt,
and defendant's mother, laVonda Peterson
Address
227 South 17th Street
Harrisburg, P A
ilia
late July 1997
to early August 1997
Plaintiff, Morgan, Kelly
Klingensmith, and her children,
Micbael and A1isba
Salem Acres Mobile Home Park
62110 Carlisle Pike, lot 301
Mcchanicsburg, PA
early July 1997
to late July 1997
Plaintiff. Morgan, and
defendant
Salem Acres Mobile Home Park
6280 Carlisle Pike, Lot 411
Mechanicsburg, PA
The plaintiff, the mother of the child, is Dorian Kay Gee, currently residing at Salem Acres Mobile
June II, 1997
to early July, 1997
Home Park, 6280 Carlisle Pike, lot 411, Mechanicsburg. Cumberland County, Pennsylvania,
She is single,
The plaintiff' currently resides with the following persons:
~
Andrea Jo-Marie Peterson
Morgan Gee
RelationshiD
her daughter
her daughter
The defendant, the father of the child, is John Clarence Peterson, III. currently residing on
Whitehall Street, Harrisburg, Dauphin County, Pennsylvania,
He is single,
The defendant currently resides with the following persons:
~
laVonda Peterson
BOMie and Bob Parthemore
Brillany, Tristan, Summer, Peyton,
Bobby, Jr" and infant
RelationshiD
his mother
his sister and brother-in-law
The Parthemore children
IS, The plaintiff has not previously participated in any litigation concerning custody of
the above mentioned child in this or any other Court,
I
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16, The plaintitl' has no knowledge of any cllstody proceedin~s concerning this child
pending before a cOllrt in this or any other jurisdiction,
17, The plainlill' does not know of any person not a party to this action who has
physical custody 01' the child or claims to have custody or visitation rights with respect to the
child,
\8, The best intere\ts and permanent welfare of the minor child will be met if custody
is temporarily granted to the plaintiff pending a hearing in this mailer for reasons including:
a, The plaintilT has provided lor the emotional and physical needs of
the child since her birth and is a responsible parent who can best care for
the minor child,
b, The defendant has shown by his abuse of the plaintiff that he is not
an appropriate role model lor the minor child,
WHEREFORE, pursuant to the provisions of the "Protection from Abuse Act" of October
7,1976,23 P,S, ~f.i101 !:l,$~II, as amended, the plaintilfprays this Honorable Court to grant the
following relief:
A. Grant a TemporlrY Order punuant to the "Protection rrom Abuse
Act:"
\, Ordering the defendant to refrain from abusing the plaintiff or from
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, written,
third party, or electronic communications;
3, Ordering the defendant to refrain from harassing and stalking the
plaintiff and from harassing her relatives;
, _-0_"-
4, Prohibiting the defendant Irom going to Ihe plaintilfs place of
employment or the day care facility of the minor child;
5, Prohibiting the delimdant Irom damaging or destroying any
property jointly owned by the parties or owned by the plaintill;
6, Granting possession of the mobile home 10catl.'<I at Salem Acres
Mobile Home Park, 6280 Carlisle Pike. Lot 411, Mechanicsburg,
Cumberland County, Pennsylvania, to the plaintill'to the exclusion of the
delendant, and ordering the detendant to stay away Irom any residence the
plaintilTmay establish tor herself pending a linal order in this matter;
7, Granting temporary custody of the parties' minor child, Andrea Jo-
Marie Peterson, to the plaintitl;
9, Ordering the defendant to relinquish to the sherilfs department any
weapons which he owns or possesses including, but not limited to, a
shotgun, and prohibiting the defendant Irom acquiring or possessing any
weapons for the duration of the Temporary Protection Order,
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 eITeet for a period of one year:
I , Ordering the delendant to relrain from abl.lsing the plaintiff or from
placing her in fear of abuse,
2, Ordering the delendant to relrain from having any direct or indirect
contact with the plaintilf including, but not limited to. telephone, wrillen,
third party, or electronic communications;
3. Ordering the defendant to relrain from harassing and stalking the
plainlill' and from harassing her relatives;
4, Prohibiting the defendant from going to the plaintill's place of
employment 0- the dl.lY care facility of the minor child;
5, Prohibiting the detimdant frorn damaging or destroying property
jointly owned by the parties or owned by the plaintitf;
6, Granting possession of the mobile home located at Salem Acres
Mobile Home Park, 6280 Carlisle Pike, lot 411, Mechanicsburg,
Cumberland County, Pennsylvania, to the plaintill'to the exclusion of the
defendant, and ordering the defendant to stay away from any residence the
plaintiff may establish for herself;
7, Ordering the detendantto relinquish to the sherin's department any
weapons which he owns or possesses including, but not limited to, a
shotgun, and prohibiting the defendant from acquiring or possessing any
weapons for the duration of the Protection Order;
8, Ordering the defendant to pay $250,00 to Cumberland County, one
of legal Services, Inc, 's funding sources, as reimbursement for the cost of
litigating this case, and assessing the $25,00 surcharge and court costs to
the defendant if the case goes to hearing,
The plaintiff further asks that this Petition be tiled and served without payment of fees and
costs by the plaintiff, pending a further order at the hearing, and that a certified copy of this
Petition and Ol'der be delivered to the Harnpden Township Police Department which has
jurisdiction to enforce this Order,
The plaintiff prays for such other relief as may be just and proper,
, ,
The above-named plaintift: Dorian Kay <lee, verities that the statements made in the above
Petition are true and correct. The plaintift' understands that talse statements herein arll made
subject to the penalties of 18 Pa C S, ~4l)04 r~lating to unsworn lalsilication to authorities,
Date' _ ,t!. :!(._~~~__ _ _ _ _ J) ~l ~ i~_____
Dorian Kay Gee, Plaintiff
.1
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LEGAL SERVICES, INC.
8 Irvine Row
Carlisle, Pennwlvlnla 17013
(717) ~~3.Y400
Fax ('117) 243.8026
Wesl Shore (717) 766-&475
,......- ....
-. ~' ,fAl72D1
1111)
":1. W4'''1l,,~h,","'"'
u..1)'IMIIJ.1'~"" mu
11I1)~"1l
December 9, 1997
John Clarence Peterson DI
clo Lavonda Peterson
917 South 17th Street
Harrisburg. P A 17
Me, Peterson:
Ma, Gee recently came to our office to discuss incidents which have occurred since approximately
September, 1997, in which she says you have harassed her, threatened to physically abuse her.
intimidated her, stalked her, and come to her hDme uninvited and after you were evicted from
elMon's Mobile Home Park,
This letter is to inform you that you are not to go to Ms. Gee's residence again and officially gives
you notice that you will be considered a deliant trespasser if you do go to her residence, The
penalty for defiant trespass is up to one year imprisonment.
Ms, Gee has been advised of the crimina; and civil remedies available to her in Pennsylvania, You
should be aware that the criminal laws apply to acts of violence even when they occur persons
who have been intimately involved, The penalty for simple assault, which can include "attempts
by physical menace to put another in fear of imminent serious bodily injury" is up to two years
imprisonment and a SS,ooo,oo line, For harassment (including striking. shoving. kicking,
alarming or seriously 1M0ying a person), the punishment is up to a S3oo,oo fine and 90 days
imprisonment. Harassment by communication is also a crime punishable by up to one year in
prison or a S2500 line, The crime of stalking includes engaging in a coune of conduct such as
following someone without proper authority intending to cause the person fear of bodily injury or
substantial emotional distress, Stalking is punishable by imprisonment for up to seven years,
Ms, Gee has also been ddvised of a civil remedy available under the Protection From Abuse Ac..1,
Under this Act, she can petition the coun to issue a Protective Order, [f such an order is entered,
it win be placed on file with the police, and if you violate the order, you will be taken before the
judge who issued the order, The judge will then decide what punishment is appropriate, A
person who violates such an order ca[YCHtfHTiA>r up to six months and/or assessed a
Slooo line.
SERVING ADAMS, CUMBERLAND, FRANKLIN AND FULTON COUNTIES
.
...
8, This Order shall reaain in effect for a period of one (1) year and
can be extended beyond that t h.e if the Court finds that the defendant haa
committed an act of abuse or has engaaed in a pattern or practice that indicates
riek of harm to the plaintiff, This Order shall be enforceable in the same
-.nner as the Court's prior Temporary Protection Order entered in this case,
9, This Order IIaY subject the defendant to: i) arrest under 23 Pa.C,S,
86113; ii) a private criminal complaint under 23 Pa,C,S, 86113,1; iii) a charge
of indirect criminal contempt under 23 Pa.C.S, 86114, 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. 86114,1, Resu.ption of co-residence on the part of the plaintiff and
defendant shall not wllify the proviaions of the court order,
10. The Hampden Township 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 violat ion is
conmitted 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 unavlIllable, the
defendant shall be taken before the appropriate district justice. (23 Pa,C.S. 8
6113) ,
By the Court.
If l;el~f:!./fr. ~~ ~ '
Joan Carey
LI!DAL SI!RVI CI!8. IHe.
Attorney for Plaintiff
TRUE COPY FROM RECORD
In T ffSltmony wlltr8of, I here unto SIlt my IIand
};"1s '~t $.i~J Court 31 Cclrl/s!e PI'
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PioAt"";".,,p. \
John Clarence Peterson, 111
Defendant
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DORIAN KAY GEE,
Plaintift'
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY. PENNSYLVANIA
v,
NO. 96-2855 CIVIL TERM
JOHN CLARENCE PETERSON. III.
Defendant
PROTECTION fROM ABUSE
PROTECTION ORDER
AND NOW. thisZ,'7.1\ay of June. 1991l. upon consideration of the Consent Agreement
ofthe parties, the following Order is entered:
I. The defendant. John Clarence Peterson. III, is enjoineiJ trom physically abusing the
plaintiff, Dorian Kay Gee. or from placing her in fear of' abuse,
2, The defendant is enjoined trom having any direct or indirect contact with the
plaintiff including, but not limited to. telephone. wrillen. third party. or electronic
communications,
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 damaging or destroying any property owned by
the plaintiff or jointly owned by the panies,
6, The defendant is excluded from the plainlill's residence located at Salem Acres
Mobile Home Park. 6280 Carlisle Pike, 1.01 411. Mechanicsburg. Cumberland County.
Pennsylvania, and is ordered 10 stay away from any residence the plaintiff' may in the future
establish for herself
7, Coun costs and fees are waived
I
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DORIAN KAY GEE,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v,
NO. 96-2855 CIVil. TERM
JOHN CLARENCE PETERSON, III,
Defendant
PRO I'ECTlON FROM ABUSE AND CUSTODY
CONSENT AGREEMENT
'1'--
This Agreement is entered on this f5_ day of June, 1998, by the plaintilf, Dorian Kay Gee,
and the defendant, John Clarence Peterson, III, The plaintill' is represented by Joan Carey and
Philip C. Briganti 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,
I. The defendant, John Clarence Peterson, III, agrees to refrain from abusing the
plaintiff, Dorian Kay Gee, or from placing her in lear of abuse,
2, The defendant agrees not to have any direct or indirect contact with the plaintiff
including, but not limited to, telephone, written, third party or electronic communications,
3. The defendant agrees not to harass and stalk the plaintiff and 1I0t to harass the
plaintiffs relatives,
4, The defendant agrees not to go to the plaintiffs place of employment or the day
care facility of the minor child,
5, The defendant agrees not to damage or destroy any property owned by the plaintiff
or jointly owned by the parties,
6, The defendant agrees to stay away from the plaintiffs residence located at Salem
Acres Mobile Home Park, 6280 Carlisle Pike, Lot 411, Mechanicsburg. Cumberland County,
Pennsylvania, and agrees to stay away from any residence the plaintiff may in the future establish
for herself
7, The defendant, although entering into this Agreement, does not admit the
allegations made in the Petition,
8, The defendant agrees to relinquish to the sheritl's department any weapons which
he owns or possesses including, but not limited to, a shotgun, and agrees not to acquire or
possess any w"apons for the duration of the Protection Order.
9, The defendant understands that the Protection Order entered in this matter will be
in effect for a period of one (I) year and can be ex:tended beyond that time if the Court finds that
the defendant has committed an act of abuse or has engaged in a pallern 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, ~6113; ii) a private criminal complaint under 23 Pa,C.S, ~61I3,I; iii) a charge of indirect
criminal contempt under 23 Pa,C,S, ~6114, punishable by imprisonment up to six months and a
fine ofS I OO,OO-S I ,000,00; and Iv) civil contempt under 23 Pa,C S, ~6114,1.
WHEREFORE, the parties request that a Protection Order be entered to reflect the above
terms,
0Cl~~L~
Dorian Kay Gee, Plaintiff
/ f~ / /
-IJ::(t./~ (i'l"'X:
Joan Carey r-
Philip C. Briganti
Attorneys for Plaintiff
/~~v C:f)J~/ $
~~arence Peterson, III, Defendant
1/'
UGAL SERVICES, INC.
8 Irvine Row
Carlisle, PA 17013
(717) 243-9400
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