HomeMy WebLinkAbout96-03200
KAREN SAPORITO,
Plaintitf
IN THE COURT OF COMMON PLEAS OF
v.
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 96- -I J,'O CIVIL TERM
ANDREW SAPORITO,
Defendant
PROTECTION FROM ABUSE
TEMPO~ROTECTION ORDER
AND NOW, this ~ day of June, 1996, upon present3tion
consideration of the within Petition, and upon finding that
and
the plaintiff, KAREN SAPORITO, now residing at 507 North pitt
street, Carlisle, Cumberland county, Pennsylvania, is in
immediate and present danger of abuse from the defendant, ANDREW
SAPORITO, the following Temporary Order is entered.
The defendant, ANDREW SAPORITO, SSN:204-58-3446 and
DOB:7/14/78, is currently incarcerated at the Schaffner Detention
center, Dauphin County, Pennsylvania, is hereby enjoined from
physically abusing the plaintiff, KAREN SAPORITO, or placing her
in fear of abuse.
The defendant is excluded from the plaintiff's residence
located at 507 North pitt Street, carlisle, Cumberland County,
Pennsylvania, a residence which is owned by the plaintiff.
The defendant is ordered to refrain from having any direct
or indirect contact with the plaintiff including, but not limited
to, telephone and written communications.
The defendant is enjoined from harassing and stalking the
plaintiff and from harassing the plaintiff's relatives.
The defendant is enjoined from entering the plaintiff's
place of employment.
The defendant is enjoined from removing, damaging,
destroying or selling any property owned by the plaintiff.
A violation of tbis Order mkY subject tbe detendant tOI i)
arreet under 23 Pa. C.B. 56113; ii) a privata criminal complaint
under 23 Pa. C.S. 56113.1; iii) a cbarqe of indirect criminal
contempt under 23 Pa. C.S. 56114, puniebable by imprisonment up
to six montbs and a tine ot $100.00-$1,000.00; and iv) civil
contempt under 23 Pa. C.S. 56114.1. Resumption ot co-residence
on the part ot the plaintitt and defendant shall not nullify the
provisions of tbe court order.
This Order shall remain in effect until modified or
terminated by the Court after notice or hearing and can be
extended beyond its original expirati~n date if the Court finds
that the defendant has committed another act of abuse or has
engaged in a pattern or practice that indicates continued risk of
harm to the plaintiff.
A hearing shall be held on this matter on the
'-l r~.
I day of
June, 1996, at
'i ,-I' ,\.m., in Courtroom No...l....., Cumberland
County Courthouse, Carlisle, Pennsylvania.
The plaintiff may proceed without pre-payment of fees
pending a further order after the hearing.
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
by mail.
The Carlisle Police Department and the Carlisle Army War
College Military Police shall 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 co~tempt 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, the arresting officer shall
file a complaint with the JUVENILE COURT. The provisions
relating to detention shall be addressed to the on-duty probation
officer, and the matter shall be scheduled promptly for
processing, adjudication and disposition with the judge scheduled
to deal with juvenile matters.
By the court,
Judge
You have been sued in court. If you wish to defend against
the claims set forth in the following pages, you must take action
promptly after this Petition, Order and Notice are served, by
appearing personally or by attorney 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 requested 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 $25.00 will be assessed against
you. You may also be required to pay attorney fees to Legal
Services, Inc. for their representation of the plaintiff.
You should take this paper to your lawyer at once. It you
do not have a lawyer or cannot afford one, qo to or telephone the
attice set torth below to find out where you can qet leqal help.
COURT ADMINISTRATOR, 4th FLOOR
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PENNSYLVANIA 17013
TELEPHONE NUMBER: (717) 240-6200
AMERICANB WITH DISABILITIEB 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 made at least 72 hours prior to any hearing or business
before the court.
KAREN SAPORITO,
Plaintiff
v.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 96- J':;<l~' CIVIL TERM
ANDREW SAPORITO,
Defendant
PROTECTION FROM ABUSE
PETITION FOR PROTECTION ORDER
RELIEF UNDER THE PROTECTION FROM ABUSE
ACT, 23 P.S. S 6101 et seq.
A. ABUSE
1. The plaintiff, KAREN SAPORITO, is an adult individual
residing at 507 North Pitt Street, CarliSle, Cumberland County,
Pennsylvania 17013.
2. The defendant, ANDREW SAPORITO, SSN:204-58-3446 and
008:7/14/78, is a minor currently incarcerated at the Schaffner
Detention Center, Dauphin County, Pennsylvania.
3. The defendant is the son of the plaintiff.
4. Since approximately 1992, 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 plaintiff under circumstances which have placed
the plaintiff in reasonable fear of bOdily injury. This has
included, but is not limited to, the following specific instances
of abuse:
a. On or about May 27, 1996, the defendant threw a
wooden canister at the plaintiff striking her in the
chest and stomach, brandished an iron while screaming
at the plaintiff, and struck the wall with the iron
several times making holes in the wall. The defendant
then went after the plaintiff who dropped to the ground
to protect herself, raised his fists as if to hit her,
screamed obscenities at her, and threatened to kill
her. The defendant then went into the living room,
kicked the wall and left. The plaintiff locked the
door and telephoned the defendant's probation officer,
Dirk Madison, who took the defendant into custody. The
defendant is currently incarcerated at the Schaffner
Detention Center.
b. In or around the beginning of May 1996, the
defendant threatened the plaintiff saying, "Get out of
my way or I'll kill you." The plaintiff, fearing for
her safety, went into her bedroom, locked the door, and
called 911.
c. In or around the end of April 1996, the defendant
repeatedly punched the plaintiff's dog with his fist.
When the plaintiff attempted to stop the defendant, he
threatened to kill her.
d. In or around the beginning of April 1996, the
defendant swiped his arm across the counter, knocking
the canisters off of the counter and breaking them, and
threatened the plaintiff Rftying, "One of these days I'm
going to knock the fuck out of you."
e. In or around March 1996, the defendant punched his
brother in the face, breaking the eye orbit.
f. In or around 1992, the defendant repeatedly shoved
the plaintiff against a wall. The plaintiff called the
Carlisle Police who arrested the defendant for assault.
Several days later, the defendant punched his brother
in the eye, knooking him semi-conscious, jumped on his
ribs, and kioked him the head, causing a concussion.
g. Sinoe the defendant has been incarcerated on
approximately May 27, 1996, he has made repeated
threats to his probation officer that he would beat the
plaintiff to death so it would take longer and she
would suffer more, and that when the defendant was
done, he'd out off the plaintiff's head and feed it to
the dog.
5. The plaintiff believes and therefore avers that she is
in immediate and prescant danger of abuse from the defendant
should she remain in the home without the defendant's exclusion
and that she is in need of protection from such abuse.
6. The plaintiff desires that the defendant be prohibited
from having any direot or indirect contact with the plaintiff
inoluding, but not limited to, telephone and written
oommunioations.
7. The plaintiff desires that the defendant be enjoined
from harassing and stalking the plaintiff, and from harassing the
plaintiff's relatives.
8. The plaintiff desires that the defendant be restrained
from entering her place of employment.
9. The plaintiff desires that the defendant be enjoined
from removing, damaging, destroying or selling any property owned
by the plaintiff.
B. EXCLUSIVE POBSESSION
10. The home from which the plaintiff is asking the Court
to exclude the defendant is owned in the name of the plaintiff.
C. REIMBURBEMBNT FOR cOBT OF CASE
11. The plaintiff asks that the defendant be ordered to pay
$250.00 to reimburse one of Legal Services, Inc.'s funding
sources for the cost of litigating this case.
WHEREFORE, pursuant to the provisions of the "Protection
from Abuse Act" of October 7, 1976, 23 P.S. S 6101 et sea., as
amended, the plaintiff prays this Honorable Court to grant the
following relief:
A. Grant a Temporary Order pursuant to the
"Protection from Abuse Act:"
1. 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;
3. Ordering the defendant to refrain from
harassing and stalking the plaintiff and from
harassing the 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. Granting possession of the home located at
507 North pitt street, Carlisle, Cumberland
County, Pennsylvania, to the plaintiff to the
exclusion of the defendant pending a final order
in this matter, and from any other residence she
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 hearing, enter an order to be in effect for a period of
one year:
1. 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 the 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. Granting possession of the home located at
507 North pitt street, Carlisle, Cumberland
county, Pennsylvania, to the plaintiff to the
exclusion of the defendant, and to stay away from
any other residence she may establish for herself
in the future.
7. ordering the defendant to pay $250.00 to
reimburse one of Legal services, Inc.'s funding
sources for the cost of litigating this case.
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 a certifiad copy
of this Petition and Order be delivered to the Carlisle Police
who has jurisdiction to enforce this Order.
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7. The Cour.t costs and fees are waived.
8. This Order shall remain in effect for a period of one
(1) year 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 on a continued basis. This Order shall
be enforceable in the same manner as the Court's prior Temporary
Protection Order entered in this case.
9. This Order may subject the defendant to: i) arrest
under 23 Pa, C.S. S6113; ii) a private criminal complaint under
23 Pa, C.S. S6113.1; iii) a charge of indirect criminal contempt
under 23 Pa, C.S. S6114, 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. S6114.1. Resumption of co-residence on the
part of the plaintiff and defendant shall not nullify the
provisions of the court order.
10. The Carlisle and Carlisle Army War College Military
Police Departments shall be provided with certified copies 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 violation is committed in the presence of the pOlice officer.
In the event that an arrest is made, the arresting officer shall
file a complaint with the JUVENILE COURT. The provisions
relating to detention shall be addressed to the on-duty probation
officer, and the matter shall be scheduled promptly for
--...11\..,.'
6. The defendant agrees to stay away from the plaintiff's
residence located at 507 North Pitt Street, Carlisle, Cumberland
County, Pennsylvania, and 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.
a. The defendant understands that the Protection Order
entered in this matter will be in effect for a period of one (1)
year 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 on a continued basis. 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.
9. Violation of the Protection Order may subject the
defendant to: i) arrest under 23 Pa, C.S. 56113; ii) a private
criminal complaint under 23 Pa, C.S. 56113.1; iii) a charge of
indirect criminal contempt under 23 Pa. C.S. 56114, 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. 56114.1.
WHEREFORE, the parties request that a Protection Order be
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INSTRUCTIONS TO THE DEFENDANT
As you know, the plaintiff has filed a legal action against you under the Protection
From ."buse Act and has obtained a Temporary Protection Order. The plaintiff is prepared
to have 11 hearing held in order to obtain a final Protection Order effective for one (1) year.
II/J an alternative, you may lXmsent to the entry of the final Protection Order to be in
effect for one year. If you are IrilUng to consent you should call Legal Services, Ine. in
Carlisle at 243-9400, 766-8475 from the West Shore or 530-5866 from Shippensburg, and ask
to speak to the stafr person hanrllina the case about II Omsent Agreement.
The Consent Agreement should be prepared before the time scheduled for the hearing
so the Court will know ahead of time that the case will not be contested. In some cases,
regardleas of whether a settlement by Consent Agreement has been reached, the parties
must appear in court at the time scheduled for hearing. If the case is uncontested, the
court appearance will be brief. The judge will make sure the parties understand the
Consent Agreement and final Protection Order.
If you do not aaree to the entry of the final Protection Order, a contested hearing will
take place at the scheduled tin!e. When a final Protection Order is entered, it will be sent or
given to you, the plaintiff, and the appropriate police departments. If you fail to abide by
the terms of the final Protection Order you will be subject to immediate arrest, and a fine of
$100.00 to $1,000.00 and/or a jail sentence of up to six months and other relief.
PEES AND COSTS
If the case goes to hearing and the judge grants a Protection Order, a surcharge of
$25.00 will be assessed against you. You may also be required to pay attorney fees to Legal
Services, Inc. for their representation of'the plaintiff.
YOU SHOULD TAKE TIllS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE TIlE OFFICE SET FORTH BELOW TO
FIND OUT WHERE YOU CAN GET LEGAL HELP.
COURT ADMINISTRATOR, 4th FLOOR
CUMBERLAND 'COUNTY COURTHOUSE
CARLISLE. PENNSYLVANIA 17013
TELEPHONE NmlBER: (717) 240-6200
The defendant is enjoined from entering the plaintiff's
place of employment.
The defendant is enjoined from removing, damaging,
destroying or selling any property owned by the plaintiff.
A violation of this Order may subject the defendant tOI i)
arrest under 23 Pa. C.S. 56113; ii) a private oriminal complaint
under 23 Pa. C.S. 56113.1; iii) a cbarge of indirect criminal
contempt under 23 Pa. C.S. 56114, punishable by imprisonment up
to six .ontbs and a tine of $100.00-$1,000.00; and iv) civil
contempt under 23 Pa, C.S. 56114.1. Resumption of co-residence
on tbe part ot the plaintiff and defendant shall not nullify tbe
provision. ot the court order.
This Order shall remain in effect until modified or
terminated by the Court after nOtice or hearing and can be
extended beyond its original expiration date if the Court finds
that the defendant has committed another act of abuse or has
engagQd in a pattern or practice that indicates continued risk of
harm to the plaintiff.
A hearing shall be held on this matter on the /~fh day of
June, 1996, at IO:C)()fl .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 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 ohall not send a copy of this Order to the de fondant
by mail.
The Carlisle Police Department and the Carlisle Army War
College Military Police shall 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 ~ade, the arresting officer shall
file a complaint with the JUVENILE COURT. The provisions
relating to detention shall be addressed to the on-duty probation
officer, and the matter shall be scheduled promptly for
p~ocessing, adjudication and disposition with the judge scheduled
to deal with juvenile matters.
By the Court,
/5'/0r,o
(' i:4
udge
TRUE COPY FROM RECORD
In Testimony whereof, I here unto set my hand
and the seal 01 said Court at Carlisle, Pa.
This '7~'1 day ,OI.Jl--~.. 19C;'v
l.......('- I.) Jll(!'~l.t\\nl~' lr).,,;t'l
Prothonotal'\l '
- . ..... ......}
You have been sued in court. If you wish to defend against
the claims set forth in the fOllowing pages, you must take action
promptly after this Petition, Order and Notice are served, by
appearing personally or by attorney 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
tail to do so the Court may proceed without you, and a jUdgment
may be entered against you by the Court without further notice
tor any money claimed in the Petition or for any other claim or
relief requested by the plaintiff. You may lose money or
property or other rights important to you.
FEEB AND COSTS
If the case goes to hearing and the judge grants a
Protection Order, a surcharge or $25.00 will be assessed against
you. You may also be required to pay attorney fees to Legal
Services, Inc. tor their representation of the plaintiff.
You should take tbis paper to your lawyer at once. It you
do not have a lawyer or cannot attord one, go to or telephone the
ottice .et torth below to find out wbere you can get legal 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 made at least 72 hours prior to any hearing or business
before the court.
PETITION FOR PROTECTION ORDER
RELIBF UNDER THB PROTECTION FROM ABUSE
ACT, 23 P.S. 5 6101 et seq.
A. ABUBB
1. The plaintiff, KAREN SAPORITO, is an adult individual
residing at 507 North Pitt street, Carlisle, Cumberland County,
Pennsylvania 17013.
2. The defendant, ANDREW SAPORITO, SSN:204-58-3446 and
DOB:7/14/78, is a minor currently incarcerated at the Schaffner
Detention Center, Dauphin count9, Pennsylvania.
3. The defendant is the son of the plaintiff.
4. Since approximately 1992, 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 plaintiff under circumstances which have placed
the plaintiff in reasonable fear of bodily injury. This has
included, but is not limited to, the following specific instances
of abuse:
a. On or about May 27, 1996, the defendant threw a
wooden canister at thb plaintiff striking her in the
chest and stomach, brandished an iron while screaming
at the plaintiff, and struck the wall with the iron
several times making holes in the wall. The defendant
then went after the plaintiff who dropped to the ground
to protect herself, raised his fists as if to hit her,
screamed obscenities at her, and threatened to kill
her. The defendant then went into the living room,
kicked the wall and left. The plaintiff locked the
door and telephoned the defendant's probation officer,
Dirk Madison, who took the defendant into custody. The
defendant is currently incarcerated at the Schaffner
Detention Center. ~
b. In or around the beginning of May 1996, the
defendant threatened the plaintiff saying, "Get out of
my way or 1'11 kill you." The plaintiff, fearing for
her safety, went into her bedroom, locked the door, and
called 911.
c. In or around the end of April 1996, the defendant
repeatedly punched the plaintiff's dog with his fist.
When the plaintiff attempted to stop the defendant, he
threatened to kill her.
d. In or around the beginning of April 1996, the
defendant swiped his arm across the counter, knocking
the canisters off of the counter and breaking them, and
threatened the plaintiff saying, "Ona of these days I'm
going to knock the fuck out of you."
e. In or around March 1996, the defendant punched his
brother in the face, breaking the eye orbit.
f. In or around 1992, the defendant repeatedly shoved
the plaintiff against a wall. The plaintiff called the
Carlisle Police who arrested the defendant for assault.
Several days later, the defendant punched his brother
in the eye, knocking him semi-conscious, jumped on his
ribs, and kicked him the head, causing a concussion.
g. since the defendant has been incarcerated on
approximately May 27, 1996, he has made repeated
threats to his probation officer that he would beat the
plaintiff to death so;it would take longer and she
would suffer more, and that when the defendant was
done, he'd cut off the plaintiff's head and feed it to
the dog.
5. The plaintiff believes and therefore avers that she is
in immediate 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 protection from such abuse.
6. 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
communications.
7. The plaintiff desires that the defendant be enjoined
from harassing and stalking the plaintiff, and from harassing the
plaintiff's relatives.
8. The plaintiff desires that the defendant be restrained
from entering her place of employment.
9. The plaintiff desires that the defendant be enjoined
from removing, damaging, destroying or selling any proPQrty owned
by the plaintiff.
B. EXCLUBIVE POSSESSION
10. The home from which the plaintiff is aSking the Court
to exclude the defendant is owned in the name of the plaintiff.
C. REIMBURSEMENT POR COBT OF CASE
11. The plaintiff asks that the defendant be ordered to pay
$250.00 to reimburse one of Leg~l services, Inc.'s funding
sources for the cost of litigating this case.
WHEREFORE, pursuant to the provisions of the "protection
from Abuse Act" of October 7, 1976, 23 P.S. S 6101!l!; sea., as
amended, the plaintiff prays this Honorable court to grant the
following relief:
A. Grant a Temporary Order pursuant to the
"protection from Abuse Act:"
1. 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 comnunications;
3. Ordering the defendant to refrain from
harassing and stalking the plaintiff and from
harassing the 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. Granting possession of the home located at
507 North pitt street, Carlisle, Cumberland
County, Pennsylvania, to the plaintiff to the
exclusion of the#defendant pending a final order
in this matter, and frum any other residence she
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 hearing, enter an order to be in effect for a period of
one year:
1. 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 the 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. Granting possession of the home located at
507 North Pitt street, Carlisle, Cumberland
County, Pennsylvania, to the plaintiff to the
exclusion of the"'defendant, and to stay away from
any other residence she may establish for herself
in the future.
7. Ordering the defendant to pay $250.00 to
reimburse one of Legal Services, Inc.'s funding
sources for the cost of litigating this case.
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 a certified copy
of this Petition and Order be delivered to the Carlisle Police
who has jurisdiction to enforce this Order.
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