HomeMy WebLinkAbout96-03732
~
..
~
Q
~
-
.
"
"II'
I
I
,
"
III
I
'1
I
,.t[!
, I
-/0'
,
,
'-I'.' I,
oi
"
"
II'i"
"
I
"
i"
'I .' i ~
-d.
n,'
'I
I
'I
I
,
!;
. '
,Ii!
"
"
'\'1
" ,J
, '
"
,
,,"j,
"
'1 '
;/!",I
.'
;j"
,
"
:,'
"
'I
"
"
"
,
I ',I ,'t I
, .
'I,
,\','
"
I 1,i
',t'l
'I'
I,'
,II
"
If!
,
I
'I't
',I it
,,'
,i'
" I
(
/,
I
I
;,
" I
,I
,I' t,
I,
I
','
.,
'.'
I
j
I
I
,.'
,
.,
,
,
_\ 'I
.,
"I'
I.
'"
, "
.,
, "
"
"
"
,
'I
I j ~ i :
'j'
~ lit
I
.'1
'1
'I'
',Ii
I
,
'I ~
"
,
I
I,,'
,\)',
,) d
,
I
"
1"1 I
'i
,I
t' ',I
1
I. I
_I '.IL
I'
r,Ii-,
",
,iI
i
I q, '
1"1
" '
-i,l,
II"
,
,
,
, I
,
,
~ . I
'ii
,
I'
i.
,
I'
",
. '
(i'
,
,
I
'1
"~I.
It I J'
i-;,'-,'
I
"
"
"
,
'11',
,I!
"
.i
')
',ij
,.'
",
.11
,
,
.1
'J_I,I'!
fl,
, '
~. I . I '
"
1/
( ",';
I
YI
,
I'rl
.'
ii-I'
l!,lt
, '
n~ I !
,
'->11
I'l)-:I
.lh
"1 :1';
,
,-1'
,
I
I'
, .1
"
"
I
,.,
,
'-(,
'I
,
, '
"
., \
,
Iq
I
I
:1'
I',
.,
I',
"
,'I
"
,
"
'I
"
I
i
,
."
I'.
-I!
"
"
.,
.,
.,
"
, ,
I
,
,-I
I
'.'
,/,', :,
"
,
1:/
I
, "
Ij ,:1
iJl';"
I/)! ,
.1
I
.'
,I' ") ,
"p
,
:; /111-
"
,
'1
'ti'
,
II
.'
II,1 I,
,'11;
I"
,
J,,!,
II ,1 ,if.
I( 11'1_ I
i'l
..1.,.1
,
,
,II !
1 1-,
"11
',J
, .
,.
'1'\' 1"'
-,'_,ll"
"
"
\-"
"
ii,r!
1,1
I' .'1
ii"~
lit
.
,"~I
"
I"
,
\,;,
J;'I
I
',JI
I'
Ii) 'r
j;,),I",
/ ('I
./'
'J,I'I
"
,
"
"
"
"
.1
"I' .;/,
I _"::f//I ,I"
'I; 1" I I'
,,' 'I' ,I
}iJI-
:'Ii'
,
.1\'
"
.;
"
.,
,
'-,r jl
"
,
'[
I I
'I
,',
"I
.,
I":
1',I!
,
,
, - ~ t ,
I,
"I
\1'1
' II
','-)I
,
"
1/'
,
",
\;
. . ,
,\'-1'
Jj ~ I ,
"
,,(,,'
.,
i!'
'I'
.,
,
,-,1,
,j'l
"
,I
I",
"
"
.,
,
';1
I
"
I'
'I,
I.
"
",',:
',I,ll
1,1 j 'I
"
I' ,'II
,
.1
I
','
)_,1,:'
",
"
II,
,
,
'1 ~
'I
','
'I
,
"
, '
"
1'1'
"
, , ~ , "
ll,),
'II'
'"
"
,of I
"
,
,
i',
I"
,to,
,"
.','d '
,
I
"i'
,
'1
.,
,1',"
ii'
, f'"Ji
;' 1'1
"
,
~ ,
"
,
,
,
i'
,I,,'
I
,I
,I
,
.'
-;I
}'
,
,11 I"
,
,','
. '
,/I{\
"
[I,
I"
,
" '
II'
1,/
, ,
"
,
,Iii, '-I
".
I','
,-,IF
"1'1";' ':'
,
"
':,
"
"
1,."1
I ~
'1
. "1
I:,
\f
",;1
I-I'
,
',I, :,H',
(' "
11'
,
[F",'
,"
t-,I
l,'i/
':1 J'
"--;,,
"
,II,
'.'
/
I
"
'I'
,/'1
il,,';'!;1'
.1
,'.)
,I
,
,
,,'
I' ,-:
'./ "
FI '.l
.-(,fj'i
,,<I
, .
'i;I'
"/
'.
1,1
,,' 'I'
" III
, '
"
!f I',
"!,,, -[
"
.,
II
"
I'
.,
,
,
,
III
"
"
"
"
,
I
" I,'
,
'.'
'cdl,'
,F"
I
,j-'
,r' '
")!I!
"",/.,1,_'
, '
1,t'.lj
I'
I
'I
,.
)1' II
, ,
.,
i\
'1
'.
"
I
,
I
II!
'>It
.'
i,'
"11.,i
"
1:11/.-/
,.':i,)l,"
,
;,'1
"
'I
>I'
: ~. -; J' '
,,'
"
, -I
,dil
, "
"
,.
, .
, ,
.,
,
,I I;:
.,
\j--/ '
ri
I
,f""
"
,
, I
"_I
,
"
,
,I
>I' ,,'i-I".'II
',L"-'
"ii' ,
1-, ,
',I', ' J; I~!
". 1-,
"
, '
I"
I
I'
,
"
"
,
.,
I')
,-,
'I'
"
'1'
,.'
it
',\" "
,
.,
.'
.1
'II,' ii'
'I
" I'
.\"
,
'f'
,f' ,I
II,
.,.,
'"
" ,
,.
"
',I
"':,'
'i
'ii,
f'"
,
)-1
"j I,
','
,
Ij
.'
"
,I'
,'Ii
, ,
"
I
,
,,',I '/.
.,'
, I
.,f
;t1
}\
":f.
!'/}
,,;"',
"
Jj
jf,
".lj,
!,j'
"
: '{~
:'1..
;;;
.-,'
"
:,;t
.,1;":/;
i;l,ii
'.'
,,~
,I )J
,'~/! '
.1'"
1,'1j"_
. h~
"ll
'I
'j'\
}'
,tr.
'-,',\~
, , : ;~~;
, ,J'"
'/'11
I ~ ! J t I
" ,,/i
, I~/:~~
'Il
,"f
"';1
,(1,:'
'-Ill
. ~ I, {
'Ii
,("1
~~ \
IU~
,'.I~
',I'd
"
II
,
,
,
.I' .
.,
"
,
I
,
I, ,1.;0'
,.<11,,)\
lJ ,I;
'i' ; 11:'\
,\ ~
] !; ~_l\\, "
, ",:.!
,I\i.'i
, \:[,
'."1 '-1.1
'1",1
I ,'j, L'
,"
i
,;,
,-",!
'"
.f.1
I,;"~
" I\"'~^
,'I
","J'j
I,~~
,
, ,) ,'~
1,li
','
^
\,1",
to, telephone and written communications.
The defendant is enjoined from harassin~ and stalkin~ the
plaintiff and from harasmln~ the plaintiff's relatives.
The defendnnt Is enjoined from enterln~ the plaintiff's
plnce of employment.
The d~fendant Is enjoined from removln~, dnma~in~.
destroyln~ or sellin~ nny property owned solely by the plaintiff.
A violation of this Order may subject the defendant to: i)
arrest. under 23 PIl.C.S. g6\ 131 Ii) Ii prlVlit.C l:rlminlll complaint.
undor 23 Pa.C.S. g6113.11 III) a charge of Indirect. criminal
cont.empt. under 23 Pa.C.S. g6\14, punishable by imprisonment up to
six months and a fino of $100.00-$1,000.00; and Iv) civil
contempt under 23 Va.C.S. g6114.\. Resumption of co-residence on
t.he part of the plaintiff and defendant shall not nullify the
provisions of the court order.
This Order ahall remnln In effect. until modified or
terminated by the Court and can be ext.ended beyond it.s ori~inal
('xplr'ntlon datl! if thl! Court finds thnt the defendant. has
commit.t.ed another act. of abuse or hns engal,(od In a patt.ern or
pract.lce t.hat Indicat.es cont.inued risk of hurm to the plaintiff.
A hearing shall be h...ld on t.hls mllt.t.or on t.ho Lt:~c~ day of
July, 1996, at. 2jA.._~L..m., in Courtroom No,.!__, Cumbor'land
Count.y Courthouse, Carlisi..., Pennsylvania.
The plaint.iff mny proceed without. pre-payment. of fees
p...ndlng tl furt.her order aft.er the hearing.
The Cumberland County Sheriff's Department shall at.tempt. to
make service at the plaintiff's request and wl~hout pre-payment
of fees, but service may be accomplished under any applicable
rule of Civil Procedure.
This Ordor shall be docketed In the otflce of the
Prothonotary and forwarded to the Sheriff for Berviae. The
Prothonotary Bhall not send a copy of this Order to the defendant
by mall.
The appropriate pollee departments will be provided with
certified copies of this Order by the plaintiff's attorney, This
Order shall be enforced by any law enforcement a~ency where a
violation occurs by arrest for Indirect criminal contnmpt without
warrant upon probable calise that this Order has been violated,
whether or not the violation In committed In the presence of the
pollee officer. In the event that an arrest Ib made under this
section, the defendant shall bc taken without unnecDssary 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.e.s. ~ 6113).
By the Court,
police officer saw the defendant attempt to punch the
plaintiff in the face, and arrested the defendant
placing him in L,comlng Count, Prison. As a result of
the abuse b, the defendant, the plaintiff sought
medical treatment at Hal, Spirit Hospital for bruises,
cuts, and a sore Jaw.
b. On or about June 29, 1996, the defendant grabbed
the plaintiff by the Jaw, slapped her In the head und
arms causing bruises, grabbed her by the wrist causing
bruises, and grabbed her by the hair pulling her off of
a bed.
c. On or about June 27, 1996, the defendant grabbed
the plaintiff by the hands tr,lng to pull her into his
room, repeatedly slapped her In the head, pushed her
down onto a floor, and grabbed her by the arms.
d. On severnl different occasions since March 1996,
the defendant has kicked the plaintiff, punched her,
and slnl>pl\ll her' In the hend and arms.
6. The plaintiff believes and therefore avers that she is
in immediate and present danger of abuse from the defendant and
that she is In n"ed of protection from sllch abuse.
6. The plaintiff desires that the defendant be prohibited
from having 8ny direct or Indirect contact with the plaintiff
Including, but not limited to, telephone and written
communications.
3
7. The plaintiff desirus that the defendant be enjoined
from harassing and BtalkLng the plaintiff, and from harassing the
plaintiff's relatives.
8. The plaintiff desIres that the defendant be restrained
from entering her plnce of employment.
9. The plaintiff desires that the defendant be enjoined
from removing, damaging, destroying or selling nny property owned
solely by the plaintiff.
1l.L-.....E.lilll&lU.~~li.Ire.5.I91i
10. The home whIch the plaIntiff la Bsking the Court to
order the defendant to stny away from is not owned or rented In
the defendant's name.
11. The defendant has his own reaidence located at 25 S.
Fou,\"th Street, Harrisburg, Pennsylvania.
c. r.oSSES-AND RE [l.:I1l.!l.M.EMliliT.1QJL!;Q5T-OJI CASE
12. The plnintiff hns suffered loaoes ns a result of the
abuse by the defendant. The losses aN' listed on ~~xhibit A
attal:hed.
13. The plaintiff asks that the defendant be ordered to pay
$250.00 to relmbul'SI! 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 Pa.C.S. g 6101 !ll "g., as
amended, the plaintiff prays this Honorable Court to grant the
following relief:
..
A. O~ant a Tempo~8~y O~da~ pu~suant to the
,ijP~oteQtion f~om Abuse Actlij
1. O~do~ing the defendant to ~ef~ain f~om
abuBing the plaintiff or placing her in fea~ of
abuBe.
2. Ordering the defendant to refrain f~om having
any direct or indirect contact with the plaintiff
including, but not ll,mlted to, telephone and
written communications.
3. Ordering the defendant to refrain f~om
harassing and stalking the plaintiff and from
haraBBing the plaintIff's relatives.
4. Prohibiting the defendant from entering the
plaintiff's place of employment.
6. Prohibiting the defendant from removing,
damaging, destroying or selling property owned
solely by the plaintiff.
6. Ordering the defendant to stay away from the
plaintiff's current residence, and any other
residence the plaintiff may establish.
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 yearl
i. Ordering the defendant to refrain from
abusing the plaintiff or placing her in fear of
6
abuse.
2. Ordering the defendant to refrain from having
anr direct or indirect contact with the plaintiff
including, but not limited to, telephone and
written communications.
3. Ordering the defendatlt to refrain from
harassing and stalking the plaintiff and from
harassing the plaintiff's relatives.
4. Prohibiting the defendant from cntering the
plaintiff's place of employment.
5. Prohibiting the defendant from removing,
damaging, destroying or selling property owned
solely by the plaintiff.
6. Order'! ng the de fendant to stay away from the .
plaintiff's currctlt residence, and any other
residence the plaintiff may establish.
7. Ordering the dcfendant to reimburse the
plaintiff's out-of-pocket losses suffered as B
result of the abuse including but not limited to
the losses listed on the attached sheet marked
.~xhibit A.
8. Ordering the defendant to pay $250.00 to
reimburse onc of Legal Serviecs, Inc. 's funding
sourees for the cost of litigating this case.
The plaintiff further asks that this Petition be filed and
6
<::}'
~
~
.r
,.:.
n
/tj;.
'/- ( :
~,',
',J'.
J ('
rrl~;
lr!(1 I
I.
tj
,"~
<C)
..
"~
.-
"-
'"
~~
,
;'),,~
'J
,):~
0"1
1"')
,.....
I .: I')
,I:!~
iJiJ:
~;i
I,;.)
(r>
I
~.J
)
~J
'"
("
"
"
"
.' '
"
I,
"
"
,
I'
"
"
, I
"
,
I'
,
"
I, "
I,
"
I,
,
[,
Ii
, "
I,
"
,1/ I'
'I , "
I J'
'(
t~
'i'
t
i
'''-.
J
I'
!,
"
"
'ON~ '830IAl:l38 '11/D31
''<~~I/ lIeJVO uvor
91; lH pel ~:l
:I d I 0 3 Y l:l d
~uvpue",~o
S8 ~ ewu40 ',u'Q07'
'S^
l}~~U~Vld
se~ewu40 '^ SVOJ~-
WJ8l l~^~O ~&L&-96
"oN
I,
II I
01
· c . c -\ . eft .., Pl'
. _ ,,",...' -- , ... ,.- ..... .... -. ..., ,......,'1 - C. , _....
1:1 Tn!!! oun or _mm....l r c_S or :.J,.._.:::. 1_:1.... .......1..:,../, <:nr:...y ,~.,I....
Dorcas Y. Ohrulle i66
'is.
John L. Ohnl11ei6
~c.
3732 Civil 19nn 1996
--.
:~..-
~ow, July 05, 1996
==-..by cLt:U= cl:.: .5"=:1.3' cl
:9_ !, S:--:'::U::: 0:: C~G::::::.!.Al'm COt.-X'l'?, ?~ co
Dauphin C..=rr to c:::::::.: ':!:is 'N::;
~ 6:put::cn ~eL:.r ::.:u!.e u :!:: ~ ::d. :!=k cf :.:.: ?t:l.!:.::.
rg~~w-.~<~
~e:-~ ct S'~u'..:u:ti C.:u.:rr. Po..
ASca.'Vit or Semee
~OWt . ~9 -. 0' clca ',e. ,::-::-i
. ~c!:1:1
:.:.e
'.:pca
~t
~, :::u:c.:.:~ to
3- c:tn' of =e ::=~......I -
..
~
>:d -.,,.;. ~ :I:) . ~~::::L
:.::.: .:::tc:.:s
So :l.:.SWeC.
Sllc:i6 cl
C.:IWlrrl ::..
Swc:: >:d s:.:!:::c:.-.1:d l:e!=
=: ~ _ QYci
cern
::..:..'l.v1CZ
s
t9_
~cru...j..CZ
.~..n1D,1. "vTI
--------
s
r_ --.&
INSTRUCTIONS TO THE DEFENDANT
As you know, the plaintiff hlll5 med a legal action asainst you under the Protection
From Abuse Act and has obtained a Temporary Protection Order. The plaintiff ill prepared
to have a hearing held in order to obtain a finai Protection Order effective for anti (1) year.
As an alternative, you may consent to the entry of the f1nd Protection Order to be In
effect for one year. If you are willing to consent you should call Lepl Services, lnc. In
Carllllle at 243-9400, 766-8475 from the Weat Shore or 530-5866 from Sh!ppensburB, and ask
to speak to the staff peI'BOn handUng the case about a Consent Alreement.
The Consent Agreement should be prepared before the time scheduled for the hearins
so the Court will know ahead of time that the case will not be conteated. In some cases,
reBardless of whether a settlement by Consent ABreement baa been reached, the parties
must appear in court at the time scheduled for hearins. If the case ill u.ncontested, 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 agree to the entry of the final Protection Order, a contested hearins will
take place at the scheduled time. When a final Protection Order ill entered, it will be sent or
given to you, the plaintiff, and the appropriate pollce departments. If you fail to abide by
the terms of the final Protection Order you will be subject to immediate arrest, and 11 fine of
$100.00 to $1,000.00 and/or a jall sentence of up to six months and other relief.
FEES AND COSTS
If the case goes to hearing and the judge grants a Protection Order, a surchllrse of
$25.00 will be assessed against you. You may also be required to pay attorney fees to I.egal
Services, lnc. for their representation of'the plaintiff.
YOU SHOULD TAKE TIUS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORni BELOW TO
FIND OUT WHERE YOU CAN GET LEGAL HELP.
COURT ADMlNlSTRATOR, 4th FLOOR
CUMBERLAND 'COUNTY COURTHOUSE
C.\RLlSLE. PENNSYLVANlA 17013
TELEPHONE NUMBER: (717) 240-6200
to, t~lephone and written communications.
The defendant is onjoined from harassins and stalking the
plaintiff and from harassing the plaintiff's relativos.
The defendant is enjoined from entering the plaintiff's
place of employment.
The defendant is enjoined from removing, damaging,
destroying or selling any pr.operty owned solely by the plaintiff.
A violation of this Order may subject the defendant to: i)
arrest under 23 Pa.C.S. 66113; ii) a private criminal complaint
under 23 Pa.C.S. 66113.1; iii) a charge of indirect criminal
contempt under 23 Pa.C.S. 66114, punishable by imprisonment up to
six months and u fine of $100.00-$1,000.00; and iv) civil
contempt under 23 Pa.C.S. 66114.1. Resumption of co-residence on
the part of the plaintiff and defendant shall not nullify the
provisions of 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 that the defendant has
committed another act of abuse or has engaged in a pattern or
A hearing shall be held on this matter on the
July, 1996, at ~4-1J ('(-,m., in Courtroom No.">-,
to the plaintiff.
!'~daY of
practice that indicates continued risk of harm
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
This has included, but ia not limited to, the following specific
instances of abuse:
a. On or about June 30, 1996, the defendant
repeatedly slapped the plaintiff in her arms and legs
and grabbed her jaw pushing her head backwards and
causing her head to hit the back of a chair. When the
plaintiff left the residence and got into her car, the
defendnnt tried to stop her cnr by throwing a trash can
and two cinder blocks in front of her car and jumping
onto the hood of the car. The defendant repeatedly
kicked and pounded on the windshield with his fists
breaking and shattering the glass which hit the
plaintiff cutting her in several places. The defendant
then reached through the broken glass and grabbed the
car keys turning off the engine. The defendant tried
to unlock the car doors which the plaintiff held shut
because she feared for her safety. The defendant
forcefully pulled open the door, he slapped the
plaintiff in the head, grabbed her jaw, slapped her in
the arms, and pulled her out of the car. The defendant
repeatedly slapped the plaintiff in the head,
threatened to push her off a bridge and into the creek,
repeatedly pushed her, grabbed her by the jaw, pushed
her to the ground, pulled her up off of the ground,
pulled his fist back threatening to punch her. A
2
police officer saw the defendant attempt to pUnch the
plaintiff in the face, and arrested the defendant
placing him in Lrcoming Countr Prison. As a result of
the abuse br the defendant, the plaintiff sought
medical treatment at Holr Spirit Hospital for bruises,
cuts, and a sore Jaw.
b. On or about June 29, 1996, the defendant grabbed
the plaintiff br the Jaw, slapped her in the head and
arms causing bruises, grabbed her br the wrist causing
bruisea, and grabbed her br the hair pulling her off of
a bed.
c. On or about June 27, 1996, the defendant grabbed
the plaintiff br the hands trring to pull her into his
room, repeatedlr slapped her in the head, pushed her
down onto a floor, and grabbed her br the arms.
d. On severnl different occasiona since March 1996,
the defendant haa kicked the plaintiff, punched her,
and slapped her in the hend and arma.
5. The plaintiff helie~eB and therefore avers that she is
in immediate and present danger of abuse from the defendant and
that she is in need of protection from such abuse.
e. The plaintiff desires that the defendant be prohibited
from having anr direct or indirect contact with the plaintiff
including, but not limited to, telephone and written
communications.
3
7. The plaintiff desires that the defendant be enjoined
from harassing and stalking the plaintiff, and from harassing the
plaintiff's relatives.
a. The plaintiff desires that the defendant be restrained
from entering her placo of employment.
9. The plaintiff desires that the ~efendant be enjoined
from removing, damaging, destroying or selling any property owned
solely by the plaintiff.
B. EXCLUSIVE POSSESSION
10. The home which the plaintiff is asking the Court to
order the defendant to stay away from is not owned or rented in
the defendant's name.
11. The defendant has his own residence located at 25 S.
Fourth Street, Harrisburg, Pennsylvania.
C. LOSSES AND REIMBURSEMENT FOR COST OF CASE
12. The plaintiff has suffered losses as a result of the
abuse by the defendant. The losses are listed on Exhibit A
attached.
13. The plaintiff asks that the defendant be ordered to pay
$260.00 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 Pa.C.S. 6 6101 n ug., as
a~ended, the plaintiff prays this Honorable Court to grant the
following reliefl
4
A. Grant a Temporary Order pursuant to the
~Proteetion from Abuse Aetl~
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
solely by the plaintiff.
6. Ordering the defendant to stay away from the
plaintiff's current residence, and any other
residence the plaintiff may establish.
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
5
abuae.
2. Ordering the defendant to refrain from having
any direct or indirect contact with the plaintiff
including, hut not limited to, telephone and
written communications.
3. Ordering the defendant to refrain from
harassing and stalklng 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
solely by the plaintiff.
6. Ordering the defendant to stay away from the
plaintiff's current residence, and any other
residence the plaintiff may establish.
7. Ordering the defendant to reimburse the
plaintiff's out-of-pocket losses suffered as a
result of the abuse including but not limited to
the losses listed on the attached sheet marked
Exhibit A.
8. Ordering the defendant to pay $250.00 to
reimburse one of Legal Services, Inc.'s funding
sourcos for the cost of litigating this case.
The plaintiff further asks that this Petition be filed and
6