Loading...
HomeMy WebLinkAbout96-05022 \. ~ ~ ~ ...... . .. ') -- <J ~ t'1 ~) ""'/ <)0 . ~. parties' apartment, but she had left some of her belongings behind. With defendant's permission, plaintiff went to the apartment on September 5, 1996 to obtain her belongings. When defendant let her in the apartment, plaintiff realized that he was drunk. The parties began to argue. Defendant then started yelling derogatory names. He then grabbed plaintiff's hat and ripped her sunglasses off the front of her shirt and broke them in half, throwing the pieces over the side of the balcony. When plaintiff tried to leave, defendant grabbed her by the neck with his right hand and attempted to force the door shut with his left hand to prevent plaintiff from leaving. plaintiff managed to get out the door and run to a phone to call the police. The police arrived and suggested the plaintiff get a PFA. No arrest was made. b. On August 20, 1996, plaintiff was staying with a friend. The defendant arrived uninvited at the door, dr'unk and angry. Plaintiff ran out the door to the pol ice stat ion. Dehmdlult, un after her shouting, "You better run, bitch'" Whilt! plaintiff w... waiting for the officer in the police parking lol., the detf.ndanl approached her again. Plaintiff's friend rode hel blcyc1e in between the part iea to keep them apart. Del endant waa lIhout ing obscenities and threats. The Carlisle pol1ct! ellcm-t..d her hoIne. Later that evening, defendant again ,uriv",d at plalnl iff'. fr1fllld'. houBe, where plaintiff was staying, and demanded his laundry that had been mixed in with hers. PlainUfl gave It 1.0 h". friend to give to defendant, at whkh tl_ de tendallt th'....lim..d that plaintiff was "going to be one dead bit~hl" c. In June 1996, pl.lnl1ft h..<I two J"'lt lcul., IV l..~\t"'te incidents. First, plaintiff and a drunken defendant were arguing when the defendant grabbed the plaintiff by the throat with both of his hands and choked her until she passed out and fell to the floor. When she awoke, defendant said, "I know you're not dead because I see you breathing." Second, plaintiff had been visiting a friend when a drunken defendant suddenly appeared. He grabbed her by the throat with his right hand, threw her against the side of the house, and held her pinned there for several minutes as he yelled obscenities in plaintiff's face. d. OVer the course of the parties' two-year relationship, defendant's verbal abuse has escalated to physical abuse, including the following: threatening the plaintiff and her children, following plaintiff, throwing objects at plaintiff, backhanding her in the ribs, throwing beer in her face, choking her, and pushing her. e. Defendant has destroyed and disposed of plaintiff's property, both when she resided at their apartment as well as after she left. 6. Catherine H. Hempstead believes and therefore avers that she is in immediate and present danger of serious abuse from defendant and that she is in need of protection from abuse. WHEREFORE, pursuant to the proviaions of the .Protection From Abuse Act. 23 Pa.C.S. 16101 et seq., Catherine H. Hempstead pray. this Court to grant the following relief: A. Grant a TewtpOrary Order pursuant to the .Protection From Abus. Act.: 11 Directing Robert A. Keller to refrain from abusing Catherine H. Hempstead and from placing her in fear of imminent serious bodily injury either personally or through his agents; 2) Excluding Robert A. Keller from entering plaintiff's current residence or any residence that plaintiff occupies and entering onto the property of such residence; 3) Directing defendant to refrain from speaking to or telephoning plaintiff regardless of the circumstances. 4) Excluding defendant from entering plaintiff's place of employment. 5) Directing defendant to refrain from having any contact with plaintiff's children when they are visiting her. 6) Directing defendant from destroying and disposing of plaintiff's property. 7) Directing the defendant to pay the administrative costs and fees required for filing the Petition; 81 Any such other relief aa the Court deellls appropriate and just. B. Schedule a hearing in accordance with the provisions of the .Protection From Abuse Act., and after such hearing, enter an order against the defendant, to be in effect for one year, as follows t 11 Directing Robert A. Kftller to refrain from abusing Catherine H, Hempstead and from placing her in fear of imminent serious bodily injury either personally or through his agent.; ZI Excluding Robert A. Keller frOlllentering plaintiff'. current re.idene. or any nl.id.net! thAt plaintiff oc=cupi.. and entering onto the property of s~h r..tden~.