HomeMy WebLinkAbout96-05434
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William Soisson,
Plaintiff/Petitioner
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION-LAW
IN PROTECTION FROM ABUSE/CUSTODY
V.
Tina Soisson,
Defendant/Respondent
NO. 96-5434
CIVIL TERM
TEMPORARY EXTENSION OF PROTECTION FROM ABUSE ORDER
AND NOW, this q't,f day of (:;~b/r.tJ, 1997, upon presentation
and consideration of the within Petition for Extension of
Protection of Abuse Order, and upon finding that petitioner,
William Soisson, residing in Cumberland County, Pennsylvania, is in
immediate and present danger of abuse from respondent, Tina
Soisson, the following Temporary Order is entered,
1, Respondent, Tlna Soisson, is hereby enjoined from
physically abusing or harassing petitioner, William Soisson, or
placing him in fear of abuse, either personally or through his
agents.
2. Respondent, Tina Soisson, is hereby ordered to stay away
from petitioner'S residence at 511 Cocklin Street, Mechanicsburg,
CUmberland County, Pennsylvania.
3. The respondent is ordered to refrain from having any
direct or indirect contact with the petitioner including, but not
limited to, telephone and written communications.
4. The respondent is t!njoir.ed from having any contact by
phone, mail, or in person with petitioner's mother, Mrs. Noonan and
petitioner's gir~triend. ..:'<114.. ,jOlIet),
5. A Iflolatioll of th~ l;:det may subject the respondent to,
1) arrest under :;:3 P.l,C,S. ~l;111, .il 'pllV.\t.~ .::r;mlnoil complaint
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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. Resumption of co-residence on the part
of the petitioner and respondent shall not nullify the provisions
of the court order.
6. A hearing shall be held in this matter on the /?~ day
of t?d~-k.v, 1997 at .3:ll/.J I'M.. in Courtroom NO...!/.-, Cumberland
County Courthouse, Carlisle. Pennsylvania.
8. The Mechanicsburg Police Department shall be provided
with a certified copy of this Order by the petitioner'S attorney.
This Order shall be enforced by any law enforcement agency where a
violation occurs by arrest for indirect criminal contempt withvut
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, under this
section, the respondent shall be taken without necessary delay
before the court that issued the order.
When that court is
unavailable, the respondent shall be taken before the appropriate
district justice. (23 P.S, 56113).
9. The petitioner may proceed without pre-payment of fees
pending a further order after the hearing.
a. stay away from petitioner's residence at 511 Cocklin
Street, Mechanicsburg, Cumberland County, Pennsylvania.
b. refrain from having any direct or indirect contact with
the petitioner or his relatives, including, but not limited to,
telephone and written communications.
5. The Order also directs that respondent refrain from contact
with Angela Erickson, the petitioner's girlfriend. Angela Erickson
is no longer the petitioner's girlfriend. His current girlfriend
is Carla Jones
6. Tina Soisson has (a) committed one or more acts of abuse,
as defined in 23 Pa.C.S.A. S6102(al (51, subsequent to the entry of
the final order, by knowingly engaging in a course of conduct or
repeatedly committing acts toward another person under
circumstances which place the person in reasonable fear of bodily
injury and (bl engaged in a pattern and practice that indicates
continued risk of harm to William Soisson. The respondent' s
actions include;
a. On or about early March of 1997, the respondent approached
the residence of the petitioner. At 11:00 P.M., the respondent
entered the petitioner's yard, approaching the house to stand next
to a bedroom window. The petitioner's mother confronted the
respondent and told her to stay away from the residence, whereupon,
the respondent left the property.
b. The respondent has physically confronted and attempted
face-to-face communication with the petitioner on the following
occasions:
i.) In or around December, 1997. at 11;30 A.M., the
respondent approached the petitioner outside the Holiday Hair salon
in the Mechanicsburg Plaza, attempted to hug the petitioner, and
grabbed the petitioner's jacket, spinning him around. The
respondent left after petitioner's mother threatened to call the
police.
ii. I March 15, 1997, the respondent approached the
petitioner while the petitioner was in Jo-Jo's Pizza Shop, 107 W.
Main St., Mechanicsburg, hugged the petitioner, slapped the
petitioner on the arm, followed the petitioner outside and followed
the petitioner to the Colony House Apartment complex located
approximately a block away.
c. On the following dates the respondent telephoned the
petitioner at his residence;
1. I October 7, 1996 (three callsl;
ii.1 November 1, 1996;
iii.! November 6, 1996;
iv.! November 9, 1997;
v.l February 13, 1997 (twice);
vi.1 February 20, 1997;
vii.1 February 23, 1997;
viii.! March 2, 1997;
ix.1 March 12, 1997;
x.! March 13, 1997;
xi.! March 20, 1997;
xii.1 March 30, 1997;
xiii.! April 2, 1997;
xiv.! August 9, 1997 (twicel;
xv.l August 25, 1997
xvi.) August 27, 1997 (twicel
xvii.l September 3, 1997;
d. On the following dates, the respondent attempted written
communication with the petitioner;
1.) February 26, 1997 (legal envelope/letterl;
iLl February 27, 1997 (legal envelope/letterl ;
HL) March 12, 1997 (anniversary card);
iv.) March 25, 1997 (postcardl ;
v.l March 28, 1997 (letterl
e. In addition, the petitioner, to the best of his belief and
knowledege, avers that the respondent has caused various third
parties to attempt telephone communication on her behalf on at
least nineteen (19) occasions.
f. The respondent drove by the petitioner's residence on two
occasions on September 7, 1997.
WHEREFOR, pursuant to the proviSions of the "Protection From
Abuse Act" 23 Pa.C.S. 56101 et seq., William Soisson
prays this Court to grant the following relief:
A. Grant a modification the Protection From Abuse Order
dated October 10, 1996. to enjoin the respondent from contacting
Carla Jones, the petitioner'S girlfriend.
B. Grant an extension of the Protection From Abuse Order of
October 10, 1996, such that it remains in effect for one year or
until further Order of Court. pursuant to the "Protection From
Abu.. Act" I
1) Directing Tina Soiason to refrain from abu.in<)
"
William Soisson and from placing him in fear of imminent serious
bodily injury either personally or through her agents;
2) Excluding Tina Soisson from entering petitioner's
current residence or any residence that petitioner occupies and
entering onto the property of such residence;
3) Directing Tina Soisson to refrain from having any
contact by phone, mail, or in person with respondent's mother, Mrs.
Noonan and defendant's girlfriend, Carla Jones;
4) Restraining respondent from entering petitioner's
place of employment or business;
51 Directing the respondent to pay the administrative
costs and fees required for filing the Petition;
61 Any such other relief as the Court deems appropriate
and just.
C. Schedule a hearing in accordance with the provisions of
the "Protection From Abuse Act", and after such hearing, enter an
order against the respondent, to be in effect for one year or until
further order of the Court, as follows:
11 Directing Tina Soisson to refrain from abusing
William Soisson and from placing him in fear of imminent serious
bodily injury either personally or through her agents;
21 Excluding Tina Soisson from entering petitioner's
current residence or any residence that petitioner occupies and
entering onto the property of such residence.
31 Directing Tina Soisson to refrain from having any
contact by phone. mail or personal contact with petitioner's mother
Mrs. Noonan and petitioner's girlfriend, Carla Jones;
4)
Restraining
the
respondent
from
entering
petitioner's place of employment or business;
5) Directing the respondent to pay the administrative
costs and fees required for filing the Petition;
6) Any such other relief as the Court deems appropriate
and just.
Respectfully Submitted,
The Family Law Clinic
by: GaiN~~r;!~1
Certified Legal Intern
. PIa e
Robert E. Rains
Katherine C. Pearson
SUPERVISING ATTORNEY
Donald Marritz
STAFF ATTORNEY
FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
(7171 243-2968
Fax: (717) 243-3639
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william soisson,
plaintiff
: IN 'l'HE COURT OF COMMONPLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
V.
.
.
.
.
.
.
.
.
C~L ACTION-LAW
IN PROTECTION FROM ABUSE
Tina soisson,
Defendant
.
..
: NO. 96-5434
CIVIL TERM
ORDER
AND NOW, this lOt).., day of &uy 1996, upon review of
the Consent Aqreement sublllitted by the parties it is hereby
ordered:
1. Tina Soisson is ordered to refrain frolll physically
abusing or harassing, William Soisson, or placing hilll in fear of
abuse, either personally or through his agents.
2. Tina soisson is ordered to stay away frolll William
Soisson's residence at 551 Cocklin Street, Mechanicsburq,
CUlIlberland County, Pennsylvania, and his place of employment at the
Italian oven, 5220 Simpson Ferry Road, Mechanicsburq, CUlIlberland
county, pennsylvania and any other place that he uy reside or be
U1ployed during the order.
J. Tina soisson is ordered to refrain frolll having any direct
or indirect contact with Williaa Soiaaon or his relatives
including,
but not 11l1li tad to,
telephone and written
cOllllllunications. Further, 'fina soi.son i. ordered to refrain frea
contact with Angela Erickson,
4. The defendant does not aait the alleqatiolUl ude in the
petition,
5. The protection Order entered 1n th1s utter vill be In
effect for a period of one (1) year and can be extended beyond that
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William Soisson,
Plaintiff
v.
IN TIlE COURT OF COMMONPLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION-LAW
IN PROTECTION FROM ABUSE/CUSTODY
Tina Soisson,
Defendant
NO. 96-
CIVIL TERM
TEMPORARY PROTECTIVE ORDER
AND NOW, this ;)"'" day of ~-.b!.r 1996, upon presentation and consideration of the
within Petition, and upon finding that plaintiff, William Soisson, residing in Cumberland
County, Pennsylvania, is in immediate and present danger of abuse from defendant, Tma
Soisson, the following Temporary Order is entered.
1. Defendant, Tina Soisson, is hereby enjoined from physic:ally abusing or harassing
plaintiff, William Soisson, or placing him in fear of abuse, either personally or throu&h his
agents.
2. Defendant, Tma Soisson, is hereby ordered to stay away from petitioner's
residence at 551 CockJin Street, MedlanicsburJ, Cumberland County, Pennsylvania. and his
place of employment at lhc Italian Oven 5220 Simpson Ferry RaId, MedIanic:sbutJ,
Pennsylvania.
3. TIle defendant is orden:d to refrain from havinc any direct or indirect COIIIaCt with
lhc plaintiff indudinc, but noc limiltd to, telephone and written communicalions.
~. TIle defendant is enjoined from havin& any contact by pftone, mail, or in pett()Q
with defendam's IIlOClIer, Mn. Noonan and defc4u\t', ,irtfriend, Aqda Ericbon.
5, A viobcioft of Ihc Order may subj<<t Ihc dtfemtam to: i) anat IJndcr l) Pa.e,s.
~61l3; ii) a private criminal complaint under 23 Pa.C.S. ~61l3.1: Hi) a charge of indirect
criminal contempt under 23 Pa.C.S. ~6114, punishable by imprisonment up to six months and
a fine of SIOO.OO-SI,OOO.OO; and iv) civil contempt under 23 Pa.C.S. ~61l4.1. ResumptIon
oC co-resIdence on the part oC the plaintiff and deCendant shall not nullify the provisions oC
the court order.
6. A hearing shall be held in this matter on the I()~l day of oc1.. , 1996 at jO"Z~.,
in Counroom No.-4, Cumberland County Courthouse, Carlisle, Pennsylvania.
8. The Mechanicsburg Police Department shall be provided with a certified copy of
this Order by the plaintifrs 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 made, under this section, the
defendant shall be taken without n........"ry delay before the coon that issued the order. When
that court is unavailable, the defendant shall be taken before the appropriate district justice. (23
P.S. 16113).
9. The plaintiff may proceed without pre-payment of fees pending a funber order
after the larine.
10. This Order shall be docketed in the offICe of the Prothonotary. The Prothonotary
shall not send a copy of this Order to the Defendant by mail.
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By the Count
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William Soisson,
Plaintiff
: IN TIlE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: CIVIL ACTION - LAW
: IN PROTECTION FROM ABUSE
Tina Soisson,
Defendant
s 434-
: NO. 96- CIVIL TERM
"..HUlON FOR PROTECTION FROM ABUSE
The petition of William Soisson respectfully represents as
follows:
1. The plaintiff, William Soisson, is an adult individual who
is reSiding at 511 Cocklin Street, Mechanicsburg, CUmberland
County, Pennsylvania 17055.
2. The defendant, Tina Soisson, is an adult individual who is
last known to reside at, 125 West Main Street Apartment 6,
Mechanicsburq, CUmberland County, PennSYlvania 17055.
3. Willi.. Soisson and Tina Soisson were married on Karch 15,
1987.
4. OVer the course of their relationahip, defendant u.
-abused" the plaintiff a. that terll is defined at 23 'a.C.8,A.
56102(a):
a. On S8pteaber 3, 1996, plaintiff wa. waiting outside of
Urisni.' "kery in MechanicsbureJ, 'A. The defendant ca.. out of
the bakery &n4 yelled an Obscenity at the plaintiff. The defendant
then struck the plaintiff in the faee causing an injury to his
, ,
face. The plaintiff subsequently reported the incident to the
police.
b. On September 1, 1996, the plaintiff was at his mother's
home. The defendant entered onto the property and made an obscene
gesture towards the plaintiff. The plaintiff told the defendant to
leave the property or he would call the police. The defendant
kicked over the plaintiff I s moped and broke the handbrake. The
plaintiff went inside and instructed his mother to call 911. The
defendant entered into the plaintiff I smother's garage and the
plaintiff went into the garage. The defendant then struck
plaintiff in the face with her right fist causing his nose to
bleed.
c. In June of 1995, defendant struck plaintiff with a lead
pipe in the arm, leg, head, and back, while the plaintiff was
sleeping, requiring 50 stitches, breaking plaintiff's nose, arm and
lower leg.
d. In June of 1995, defendant struck plaintiff in the head
with a telephone causing an injury requirinq 17 stitches.
e. In Kay of 1995, defendant hit plaintiff in the head with
a dresser drawer causing a laceration that required stitches.
f. In NOVember of 1994, Yhile plaintiff was ~oldinq their
child, defendant threw a baby walker at plaintiff, atrikinq hi. in
the head. Plaintiff's no.e was broken.
5. William Soisson believes and therefore avera that be ia in
immediate and present danger of serious abuse from defendant and
that he i. in need of protection trom abu...
WHEREfORE, pursuant to the provisions of the .Protection From
Abuse Act" 23 Pa,C.S. 56101 et seq., William Soisson
prays this Court to grant the fOllowing relief:
A. Grant a Temporary Order pursuant to the "Protection From
Abuse Act":
1) Directing Tina Soisson to refrain from abusing
William Soisson and from placing him in fear of imminent serious
bodily injury either personally or through her agents;
2) Excluding Tina Soisson from entering plaintiff's
current residence or any residence that plaintiff occupies and
entering onto the property of such residence;
3) Directing Tina Soisson to refrain from having any
contact by phone, _iI, or in person with defendant's mother, Mrs.
Noonan and defendant'. girlfriend, Angela Erickson;
4) Restraining defendant from entering plaintiff's
place of employment or business;
5) Directing the detendant to pay the administrative
costs and fees required for tiling the Petition;
6) Any such other relief as the Court dee.. appropriate
and just.
B. Schedule a hearing in accordance with the provisions of
the "Protection From Abuse Act", and atter such hearin;, enter .n
order against the defendant, to be in etfect for one year, ..
follOW.:
1) Directing Tina Soiason to retrain trea abusing
William Soi.son and fro. placing hi. in fear of iaainent serious
bodily injury either per.onally or through her agents:
2) ExclucliftCl Tina Soisson trom enterlftCl plaintiff'.
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William Soisson,
Plaintiff
v.
IN THE COURT OF COMMONPLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION-LAW
IN PROTECTION FROM ABUSflCUSTODY
TIna Soisson,
Defendant
NO. 96- s./ ~ ., CIVIL TERM
TEMPORARY PROTECTIVE ORDER
AND NOW. this-,j~ day of [1,;4/1(: 1996, upon presentation and consideration of the
within Petition, and upon finding that plaintiff. William Soisson, residing in Cumberland
County. Pennsylvania, is in immediate and present danger of abuse from defendant, Tina
Soisson, the following Temporary Order is entered.
I. Defendant, Tina Soisson, is hereby enjoined from physically abusing or harassing
plaintiff, William Soisson, or placing him in fear of abuse, either personally or through his
agents.
2. Defendant, Tina Soisson, is hereby ordered to stay away from petitioner's
residence at '51 Cocklin Street, Mecllanicsbura, Cumberland County, Pennsylvania, and his
pIacc of employlllCllt at the lIalian Oven '220 Simpson Ferry Road, Mcchanicsburg,
Pennsylvania.
3. The defendant is ordered to refraill from havina lilY direct or iIldirect conlaCt with
the plaintiff indudi"l, bulllClt limited to, tdqlhone and writlal comlllllllic:atiof.
4. The defendant is enjoined from havina lilY conlaCt by phone, mail, 01' ill pmOIl
with dehndaAl'S motIlcr, Mn. NooIlIIl and defmdanl'S ,irlfritftd. AftIda Ericban.
5. A violation of the Order may subject tile defcadant to: i) arrest IIftder 2J he.S.
G6113; ii) a private criminal complainl under 23 Pa.C.S. G6113. I; iii) a charae of indirect
criminal contempt under 23 Pa.C.S. G6114, punishable by imprisonment up to six months and
a fine of 5100.00-51,000.00; and iv) civil contempt under 23 Pa.C.S. G6114.1. Resumption
or co-residence on the part or the plaintiff and derendant shall not nullify the provisions or
the court order.
'lA- fa ',ve) A- ~ I
6. A hearing shall be held in this matter on the ~ day of(l~l' , 1996 at _ M.,
in Courtroom No.L, Cumberland County eourthouse, Carlisle, Pennsylvania.
8. The Mcchanicsburg Police Department shall be provided with a certified copy of
this Order by the plaintiffs attorney. This Order shall be enforced by any law enfortelllCllt
agency where a violation occun 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, under this section, the
defendant shall be taken without ne<<s~ry delay before the court that issued the order. When
that court is unavailable, the defendant shall be taken before the appropriate district justice. (23
P.S. 16113).
9. The plaintiff may procted without pre-paymcnt of fees pcndilll a further order
after the hearinl.
10. This Order shall be docketed in the office of the ProthonoIary. The Prothonotary
shalllIClt SCIld . copy or this Order to the Defendant by mail.
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William Soisson,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: CIVIL ACTION - LAW
: IN PROTECTION FROM ABUSE
Tina Soisson,
Defendant
.:".31
NO. 96-' CIVIL TERM
1't;IUION FOR PR0TECl10N FROM ABUSE
The petition of William Soisson respectfully represents as
foUows:
1. The plaintiff, William soiason, is an adult individual who
is residing at 511 Cocklin Street, Mechanicsburg, CUmberland
County, pennsylvania 17055.
2. The defendant, Tina Soisson, is an adult individual who is
last known to reside at, 125 West Main street Apartllent 6,
Mechanicsburg, cuab8rland County, Pennsylvania 17055.
3. William Soisson and Tina soisson were aarried on March 15,
1987.
4. OVer the course of their relationship, defendant has
wabusedw the plaintiff as that ten 18 defined at 23 Pa.C.S.A.
56102(a):
a. On Septeaber 3, 1996, plaintiff was waiting outside of
urienis' Bakery in Mechanicsburq, PA. The defendant c... out of
the bakery and yeUed an Obacenlty at the plaintiff. The defendant
then struck the plaintiff in the face causing an injury to his
. .- ---""~
--
face. The plaintiff subsequently reported the incident to the
police.
b. On September 1, 1996, the plaintiff was at his mother's
home. The defendant entered onto the property and made an obscene
qesture towards the plaintiff. The plaintiff told the defendant to
leave the property or he would call the police. The defendant
kicked over the plaintiff'S moped and broke the handbrake. The
plaintiff went inside and instructed his mother to call 911. The
defendant entered into the plaintiff's mother's qaraqe and the
plaintiff went into the qaraqe. The defendant then struck
plaintiff in the face with her riqht fist causinq his nose to
bleed.
c. In June of 1995, defendant struck plaintiff with a lead
pipe in the arm, leq, head, and back, while the plaintiff was
sleepinq, requirinq 50 stitches, breakinq plaintiff'S nose, arm and
lower leq.
d. In June of 1995, defendant struck plaintiff in the head
with a telephone causinq an injury requirinq 17 .titch...
e. In Kay of 1995, defendant hit plaintiff in the head with
a dr....r draw.r cau.inq a laceration that required .titche..
f. In Nov.mber of 1994, vhile plaintiff va. boldinq th.ir
child, defendant threv a baby valker at plaintiff, .tr1ltinq bi. in
the bead. Plaintiff'. no.e va. broken.
5. Willia. Soi..on beli.ve. and ther.fore aver. that he i. in
i..ediate and pre.ent da~er of .eriou. abuse froa defendant and
that be is in need of protection froa abu.e.
WHIRUORI, pursuant to the provi.ion. of the ttProtection rroa
-'.'.1.--'-
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--
Abuse Act" 23 Pa.C.S. 56101 et seq., William soisson
prays this Court to grant the following relief:
A. Grant a Temporary Order pursuant to the "Protection From
Abuse Act":
1) Directing Tina Soisson to refrain from abusing
William Soisson and from placing him in fear of imminent serious
bodily injury either personally or through her agents;
2) Excluding Tina Soisson from entering plaintiff's
current residence or any residence that plaintiff occupies and
entering onto the property of such residence;
3) Directing Tina Soisson to refrain from having any
contact by phone, mail, or in person with defendant'. mother, Mrs.
Noonan and defendant's girlfriend, Angela Erickson;
4) Restraining defendant from entering plaintiff'S
place of employment or business;
5) Directing the defendant to pay the administrative
costs and fees required for filing the Petition;
6) Any such other relief as the Court deus appropriate
and just.
B. Schedule a hearing in accordance vith the provisions of
the "Protection From Abuse Act., and after such hearing, enter an
order aqainst the defendant, to be in effect for one year, as
follovs:
1) Dlrectinq Tina Solsson to refrain frea abusing
Willl.. SOisson and from placing hl. in fear of i..lnent serious
bodily injury elther peraonally or throuqh her aqents;
2) ExCludll'lCJ Tina Soi..on frea enteriftCJ plaintiff'.
current residence or any residence that plaintiff occupies and
entering onto the property of such residence.
3) Directing Tina soisson to refrain from having any
contact by phone, mail or personal contact with plaintiff's mother
Mrs. Noonan and plaintiff's girlfriend, Angela Erickson;
4) Restraining the defendant from entering plaintiff's
place of employment or business;
5) Directing the defendant to pay the administrative
costs and fees required for filing the Petition;
6) Any such other relief as the Court deems appropriate
and just.
Respectfully Submitted,
The Family Law Clinic
by: ~ei
Certified Legal Intern
~ha~ 1-
SUpervisinq Attorney
45 North pitt street
carlisle, PA 17013
717-243-2968
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William soisson,
Plaintitt
: IN THE COURT OF COMMONPLEAS OF
CUMBERLAND COUNTY, PENNtlYLVANIA
CIVIL ACTION-LAW
IN PROTECTION FROM ABUSE
V.
Tina Soisson,
Detendant
NO. 96-5434
CIVIL TERM
ORDn
AND NOW, this
.
'0
day ot <JcJol.... , 1996, upon review ot
the Consent Aqreement submitted by the parties it is hereby
ordered:
1. Tina Soisson is ordered to retrain trom physically
abusinq or harassinq, William Soisson, or placinq him in tear ot
abuse, either personally or throuqh his aqents.
2. Tina Soisson is ordered to stay away trom William
Soisson's residence at 551 Cocklin Street, Mechanicsburq,
CUlIIberland County, Pennsylvania, and his place ot employaent at the
Italian OVen, 5220 Simpson Ferry Road, Mechanicaburq, CUlIIberland
County, Pennsylvania and any other place that he may reside or be
employed durinq the order.
3. Tina Soisson is ordered to retrain trom bavinq any direct
or indirect contact with William Soisson or his relative.
includinq,
11mi tad to,
but not
telephone and written
communication.. Further, Tina Soi.son i. ordered to retrain trom
contact with Anqela Erickson.
4. The detendant doe. not admit the allaqation. made in the
petition.
5. The protection Order entered in thi. matter will be in
effect for a period of one (1) year and can be extended beyond that
-'
William Soisson,
plaintiff
.
.
IN THE COURT OF COMMONPLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION-LAW
IN PROTECTION FROM ABUSE
V.
.
.
Tina soisson,
Defendant
.
.
.
.
.
.
: NO. 96-5434
CIVIL TERM
CONSENT AGRBEMENT
The parties in the above action for Protection From Abuse
agree to the following:
1. Tina Soisson agrees to refrain from physically abusing or
harassing, William Soisson, or placing him in fear of abuse, either
personally or through his agents.
2. Tina Soisson agrees to stay away from William Soisson's
residence at 551 Cocklin street, Mechanicsburg, CUmberland County,
Pennsylvania, and his place of employment at the Italian oven, 5220
Simpson Ferry Road, Mechanicsburg, CUmberland county, Pennsylvania
and any other place that he may reside or be employed during the
order.
3. Tina Soisson agrees to refrain from having any direct or
indirect contact with William Soisson or his relatives including,
but not limited to, telephone and written cODIIIIUnications. Further,
Tina Soisson agrees to refrain from contact with Angela Erickson.
4. The defendant, although entering into this agreement, doee
not admit the allegations made in the petition.
5. The defendant underatands that the protection Order
entered in this matter vill be in effect for a period of one (1)
year and can be extended beyond that time if the Court finds that
the defendant haa committed an act of abuse or has engaged in a
.
.
.
.
pattern 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.
6. 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; 111) a charqe 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 cont8lllpt under 23 PA.C.S. 56114.1. ResUlllption of
coresidency on the part of the plaintiff and defendant shall not
nullify the provisions of the Order.
WHEREFORE, the parties request that a Protection Order be
entered pursuant to the above terms.
JJ1dh, i), l~'
Williaa Soisson, Plaintiff
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W&YriI Shade
Attorney for Defendant
,:htHI\
lace
Robert E. Rains
Katherine C. Pearson
SUPERVISING ATTORNEY
Call R. Shearer
STAFF ATTOlUIEY
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IN THE COURT OF CO~~~L~~ 19W
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION-LAW
IN PROTECTION FROM ABUSE/CUSTODY
.William Soisson,
Plaintiff/Petitioner -
Tina Soisson,
Defendant/Respondent
NO. 96-5434
CIVIL TERM
TEMPORARY EXTENSION OF PROTECTION FROM ABUSE ORDER
AND NOW, this 9-tA.. day of ~V', 1997, upon presentation
and consideration of the within Petition for Extension of
Protection of Abuse Order, and upon finding that petitioner,
William Soisson, residing in Cumberland County, Pennsylvania, is in
immediate and present danger of abuse from respondent, Tina
Soisson, the following Temporary Order is entered.
1, Respondent, Tina Soisson, is hereby enjoined from
physically abusing or harassing petitioner, William Soisson, or
placing him in fear of abuse, either personally or through his
agents,
2, Respondent, Tina Soisson, is hereby ordered to stay away
from petitioner's residence at 511 Cocklin Street, Mechanicsburg,
Cumberland County, Pennsylvania.
3, The respondent is ordered to refrain from having any
direct or indirect contact with the petitioner including, but not
limited to, telephone and written communications.
". The respondent is enjoined from having any contact by
phone. mail. or in person with petitioner's mather, Mrs. Noonan and
petltioner's girlfrlend. Carla Jones,
5, A violation of the Order may subJect the reapondent to:
il arrest under 23 Pa.C,S, 16113; 11\ ~ priv~te criminal complaint
under 23 Pa.C.S. !iG113.1; iiil a charge of indirect criminal
contempt under 23 Pa.C.S, !iG114, punishable by imprisonment up to
six months and a fine of $100.00-$1,000.00; and ivl civil contempt
under 23 Pa.C.S. !iG114.1. Resumption of co-residence on the part
of the petitioner and respondent shall not nullify the provisions
of the court order.
6. A hearing shall be held in this matter on the I?~ day
of ~..., 1997 at 3'(" f,M., in Courtroom No. Lf, Cumberland
County Courthouse, Carlisle. Pennsylvania.
8. The Mechanicsburg Police Department shall be provided
with a certified copy of this Order by the petitioner'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 made, under this
section, the respondent shall be taken without necessary delay
before the court that issued the order.
When that court is
unavailable, the respondent shall be taken before the appropriate
district justice, (23 P.S. 561131.
9, The petitioner may proceed without pre-payment of fees
pending a further order after the hearing.
.
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William Soisson,
Plaintiff/Petitioner
: IN 'tHE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v,
: CIVIL ACTION - LAW
: IN PROTECTION FROM ABUSE
Tina Soisson.
Defendant/Respondent
,
NO, 96.5434 CIVIL TERM
PETITION FOR EXTENSION AND MODIFICATION OF PROTECTION FROM ABUSE
ORDER
William Soisson, by counsel, hereby requests an order,
pursuant to 23 Pa.C.S.A. 56108(e), extending the Protection From
Abuse Order that was entered by the Court on October 6, 1996. In
support of this petition, petitioner respectfully represents as
follows:
1. The petitioner, William Soisson, is an adult individual
who is residing at 511 Cocklin Street, Mechanicsburg, Cumberland
County, Pennsylvania 17055.
2. The respo~dent, Tina Soisson, is an adult individual who
is last known to reside at 144 Woods Drive, Mechanicsburg,
Cumberland County, Pennsylvania 17055.
), William Soisson and Tina Soisson were married on March 15,
1987,
4, On October la, 1996, pursuant to a Consent Agreement
submitted by the parties, the Court entered a Protection From Abuse
Order. a true copy of which ia attached and incorporated by
reference. The Order directs, in pertinent part, that respondent:
II
I"
a. stay away from petitioner's residence at 511 Cocklin
Street, Mechanicsburg, Cumberland County, Pennsylvania,
b. refrain from having any direct or indirect contact with
the petitioner or his relatives, including, but not limited to,
telephone and written communications.
5. The Order also directs that respondent refrain from contact
with Angela Erickson, the petitioner's girlfriend. Angela Erickson
is no longer the petitioner's girlfriend. His current girlfriend
is Carla Jones
6. Tina Soisson has (al committed one or more acts of abuse,
as defined in 23 Pa.C.S.A. 56102(al (5), subsequent to the entry of
the final order, by knowingly engaging in a course of conduct or
repeatedly committing acts toward another person under
circumstances which place the person in reasonable fear of bodily
injury and (bl engaged in a pattern and practice that indicates
continued risk of harm to William Soisson. The respondent's
actions include:
a. On or about early March of 1997, the respondent approached
the residence of the petitioner, At 11:00 P.M., the respondent
entered the petitioner's yard, approaching the house to stand next
to a bedroom window. The petitioner's mother confronted the
respondent and told her to stay away from the residence, whereupon,
the respondent left the property.
b. The respondent has physically confronted and attempted
face-to-face communication with the petitioner on the following
occasions:
LI In or around December. 1997, at 11:30 A.M" the
respondent approached the petitioner outside the Holiday Hair salon
in the Mechanicsburg Plaza, attempted to hug the petitioner, and
grabbed the petitioner's jacket, spinning him around. The
respondent left after petitioner's mother threatened to call the
police.
ii.) March 15, 1997, the respondent approached the
petitioner while the petitioner was in Jo-Jo's Pizza Shop, 107 W.
Main St., Mechanicsburg, hugged the petitioner, slapped the
petitioner on the arm, followed the petitioner outside and followed
the petitioner to the Colony House Apartment complex located
approximately a block away.
c. On the following dates the respondent telephoned the
petitioner at his residence:
i.) October 7, 1996 (three calls);
ii.) November 1, 1996;
iii.) November 6, 1996;
iv.) November 9, 1997;
v.) February 13, 1997 (twice);
vi,) February 20, 1997;
vii.) February 23, 1997;
viii.) March 2, 1997;
ix.l March 12, 1997;
x.) March 13,1997;
xi. I March 20, 1997;
xii.) March lO. 1997;
dii.) April 2, 1997;
xiv.) August 9, 1997 (twice);
XV,) August 25, 1997
xvi.) August 27, 1997 (twice)
xvii.) September 3, 1997;
d. On the following dates, the respondent attempted written
communication with the petitioner:
i.) February 26, 1997 (legal envelope/letter);
ii.) February 27, 1997 (legal envelopefletter);
iii.) March 12, 1997 (anniversary card);
tv.) March 25, 1997 (postcard);
v.) March 28, 1997 (letter)
e. In addition, the petitioner, to the best of his belief and
knowledege, avers that the respondent has caused various third
parties to attempt telephone communication on her behalf on at
least nineteen (19) occasions.
f. The respondent drove by the petitioner's residence on two
occasions on September 7. 1997.
WHEREFOR, pursuant to the provisions of the "Protection From
Abuse Act" 23 Pa.C.S. 56101 et seq., William Soisson
prays this Court to grant the following relief:
A. Grant a modification the Protection From Abuse Order
dated October 10. 1996, to enjoin the respondent from contacting
Carla Jones. the petitioner's girlfriend.
B. Grant an extension of the Protection From Abuse Order of
October 10. 1996. such that it remains in effect for one year or
until further Order of Court, pursuant to the "Protection From
Abuse Act" I
1) Directing Tina Soisson to refrain from abusing
William Soisson and from placing him in fear of imminent serious
bodily injury either personally or through her agents;
2) Excluding Tina Soisson from entering petitioner's
current residence or any residence that petitioner occupies and
entering onto the property of such residence;
3) Directing Tina Sois50n to refrain from having any
contact by phone, mail, or in person with respondent's mother, Mrs.
Noonan and defendant's girlfriend, Carla Jones;
4) Restraining respondent from entering petitioner's
place of employment or business;
5) Directing the respondent to pay the administrative
costs and fees required for filing the Petition;
6) Any such other relief as the Court deems appropriate
and just,
C, Schedule a hearing in accordance with the provisions of
the "Protection From Abuse Act", and after such hearing, enter an
order against the respondent, to be in effect for one year or until
further order of the Court, as follows:
1) Directing Tina Soisson to refrain from abusing
William Soisson and from placing him in fear of imminent serious
bodily injury either personally or through her agents;
21 Excluding Tina Soisson from entering petitioner's
current residence or any residence that petitioner occupies and
entering onto the property of such residence,
3) Directing Tina Soisson to refrain from having any
contact by phone. mail or personal contact with petltioner's mother
Mrs, Noonan and petitioner's girlfriend, Carla Jones;
\oIilliam soisson,
. Plaintiff
v.
IN THE COURT OF COMMONPLEAS OF
CUMBERLAND COUNTY, PENNSYLVANrA
CIVIL ACTION-LAW
IN PROTECTION FROM ABUSE
Tina Soisson,
Defendant
NO. 96-5434
CIVIL TERM
ORDER
AND NOW, this
to 1)... day ot ~... 1996, upon review ot
the Consent Agreement submitted by the parties it is hereby
ordered:
1. Tina Soisson is ordered to refrain trolll physically
abusing or harassing, Wi11ialll Soisson, or placing hilll in tear ot
abuse, either personally or through his agents.
2. Tina Soisson is ordered to stay away trolll William
Soisson's residence at 551 Cocklin Street, Mechanicsburq,
CUlllber1and County, Pennsylvania, and his place of employment at the
Italian Oven, 5220 Simpson Ferry Road, Mechanicsburq, CUlllberland
County, Pennsylvania and any other place that he may reside or be
employed during the order.
3. Tina Soisson is ordered to refrain trolll having any direct
or indirect contact with William Soisson or his relatives
including,
but not limited to,
telephone and written
cOllllllunications. Further, Tina Soisaon is ordered to refrain froa
contact with Angela Erickson.
4. The defendant doe. not admit the allegations made in the
petition.
S. The protection Order entered in thia attar w111 be in
effect for a period of one (1) year and can be extended beyond that