HomeMy WebLinkAbout96-05872
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purpose of facilitating custody arrangemcnts,
The defendant is enjoined from harassing and stalking the
plaintiff and from harassing the plaintiff's relatives.
^ violation of this Order may subject the dcfendant to: I)
arrest under 23 Pa.C.S. g61l3; ii) a private criminal complaint
under 23 Pa.C.S. g6l13.1i iii) 8 charge of indirect criminal
contempt under 23 Pa.C.S. g6114, 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. g6114.1. 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
practice that indicates continued risk of harm to the plaintiff.
Tcmporary custody of Dustin C. Poff and Sean T. Poff is
hereby awarded to the plaintiff, Kim M. Poff.
A hcaring shall be held on this matter on the ~~~'~ day of -
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, 1996, at /,;1: ,10 ii...m., in Courtroom No.L,
Cumbcrland 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 requcst and without pre-pa}ment
of fces, but scrvice may bc accomplished under uny applicablc
II. On or about October 9, 1996, the defendant got
angry, ran toward the pluintiff, und threatened her
saying, "I'll throw you out the fucking door right
now," causing the plaintiFF to feur for her safety.
b. On or about October 7, 1996, the defcndant called
the plaint i ff vi Ie numes, grabbed her by the legs and
neck, picked her up, and threw her across the room.
When the pluintiff tried to get up, the defendant
grabbed her by the arms and thrcw her onto the
floor,causing her to hit the bottom of the wooden
Framed couch. When the plaintiff again attempted to
rise, the defendant pushed her into the television
causing her to fall to the Floor, grabbed hcr under her
arms, dragged her to the door of the house, and threw
her out onto the porch telling her to "get the hell out
of here." As a result of the defendant's abuse, the
plaintiff had soreness, pain, and bruising.
c. In or about september 1996, the defendant grabbed
the plaintiff, pul led her onto the bed, and forceFully
held onto her so that she was unable to move. For
approximately one hour, whenever the plaintiff tried to
move, the defendant repeatedly pulled her back down
onto the bed causing her to fear for her safety.
d. On several diFFerent occasions since approximately
September 1994, the deFendant hus called the plaintiFF
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vile names and furcefully grabbed and held the
plaintiff causing puin.
5. The pluintiff believes and therefure uvers that she is
in Immediute and present dunger of abuse from the defendant
should she rcmain in the home without the defendant's exclusion
and thut she is in need of protection from such abusc.
6. The plaintiff desires thut the defendant be prohibited
from huving any direct or indirect contact with the plaintiff
including, but nut limited to, telephone nnd written
communications, except fur the limited purpose of fucilitating
custody arrangements.
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 dcsires that the defendant bc prohibited
from entering her place of employment.
8. EXCLUSIVE POSSESSION
9, The plaintiff currently has no permanent place to stay
with her childrcn except the murital home, and the defendant has
his mothcr in the area with whom he can stay.
10. The pluintiff desires possession of thc home so as to
give the greatest degree of continuity to the I ives of the
children and to allow them 1.0 continue their education at their
schools and to continue their school and social activities.
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from Abuse Act" of Octuber 7, 1'176, 23 Pu.C.S. ~ 11101 c_t .>Lc!l., as
amended, the plaintiff prllYs this lIonurllble Court tel grllnt the
following rcl ief:
A. Grant d Temporary Order pursuant to the
"Protection from Abuse Act:"
I. Ordering the defendant to refrain from
abusing the plaintiff and 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, tclephone and
writtcn communications, except to facilitate
custody arrangements.
J. Ordering the defendant to refrain from
harassing and stalking the plaintiff and from
harassing the plai~tiff's relatives.
4. Ordering the defendant to stay away from
theplaintiff's place of employment.
5. Granting possession of home located at 225
Eighth Street, New Cumberland, Cumberland County,
Pennsylvunia, tu the plaintiff to the exclusion of
the defendant pending u finol order in this
mot ter, except for the 1 imi ted purpose of
transferring custody of the parties' children.
The defendont shul I remllin in his vehicle ot 1111
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times during the transfer of custody.
6. Granting temporary custody of the minor
children to the plaintiff.
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. Order ing the defendant to refrain from
abusing the plaintiff and 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, telephonc 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, Ordering the defendant to stay away from the
plaintiff's place of employment.
5. Granting possession of the home located at
225 Eighth Street, New Cumberland, Cumberland
County, Pennsylvania, to the plaintiff to the
exclusion of the defendant, except for the limited
purpose of transferring custody of the parties'
chi ldren. The defendant shall remain in his
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vehicle at all times during the transfer of
custody.
6. Granting support to the plaintiff and the
minor children in an appropriate amount according
to thc support guidelines payable to the plaintiff
in the form of a check or money order, mailed to
her residence, and ordering the defendant to
provide health coverage to the spouse and minor
children, directing the defendant to pay all of
the unreimbursed medical expenses of the plaintiff
(spouse) and minor children of the defendant to
the provider or to the plaintiff when shc has paid
for the medical treatment ana directing the
defendant to moke or continue to make rent or
mortgage payments on the residence of the
plaintiff.
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 hearinR, and that a certified copy
of this Petition and Order be delivered to the New cumberland
police Department which has jurisdiction to enforce this Order.
The plaintiff prays for such other relief as may be just and
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ten days of the entry of this Order, the defendant shall give
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plaintiff .t2B80;ilO-wltich ,I..h..l f, of.t.h"..nn\ollllt....t.he defendant
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r=..nUy"w.Lthdre", from t.he I".rll et!' h..nk """ount.a. Durin!! the
time that the plaintiff resides In t.he residence to the exclusion
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of the defendant, he shall pay t.he mortg.lge payments and Lh.e. '7!iP
pM1:htiff ~hrl+pny the utility expenses.
6. The defendant is ordered to stay away from any other
residence the plaintiff may establish, except for the limited
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purpose of transferrinS custody, dtu ~lIg ..,.11~.e~ tiWAC ..he. rll3f'pndant
eh.....ll ...elUU,";'1I :n hie V4it~~rlol
7. The defendant is ordered to pay inter{\,~pport to the
plaintiff and the minor children the amount of $319.96 ~~r week,
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payable to the plaintiff in the form of a check or money order,
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by mail pending the entry of an order by the Cumberland County
Domestic Relations Office. The defendant shall make the first
payment within ten days of the entry of the Protection Order and
each week thereafter. The defendant is further ordered to
provide health coverage to the spouse nnd the minor children, and
to pay all of the unreimbursed medical expenses of the plaintiff
and the minor children t.o t.he provider or t.o the plaintiff if she
has paid for the medical treat.ment., and the defendant is ordered
conti~ue to mnke mort.gage payment.s on the residence of the
plaintiff.
8. The part.les shall at.Lend tHr--l<:ast f8ut counseling
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sessionR regarding issueR including abuse and communication.
9. The <:ollrt COHtH ",\Ii fceH nr'c w'llved.
10. ThlR Order Rhull remain In effect for a period of one
year or untiL modified or terminated by the Court. The Order can
be extended beyond ItR orl~lnul explrutlon date if the Court
has engaged In a pattern or practice that IndicateR continued
finds that the defendant haN committed another act of abUNe or
risk of harm to the plaintiff.
11. This Order may subject the defendant to: I) arrest
under 23 Pa.C.S. ~6113: Ii) a private criminal complaint under 23
Pa.C.S. ~6113.1; iil) a charge of indirect criminal contempt
under 23 Pa.C.S, ~6114, punishable by imprisonment up to six
months and a fine of $100.00-$1,000,00; and iv) civil contempt
under 23 Pa.C.S. ~6114,1. Resumption of co-re~idence on the part
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of the plaintiff and defendant shall not nullify the provisions
of the court order.
12. The New Cumberland police Department shall be provided
with a certified copy of this Order by the plaintiff'S attorney
and may enforce this Order by arrest for indirect criminal
contempt without warrant upon probable cause that this Order has
been violated. whether or not the violation is committed in the
presence of a police officer. In the event that an arrest is
made under this section. the defendant shall bo taken without
unnecessary delay before the court that issued the order. When
the residence of the plnlntlfr.
8. 'flIP. pnr'Ues shill 1 ..t.l,l!IlIl ttt;-h'..ttt;-H>tH' counseling
s"s,dons regnr'din!! iHSIWS includln!! ..buso nnd communlc..tlon.
9. TIll! derend..nt, ..Ithou!!h ent"r'lnl! into this Agreement,
does not ..dmit the all"gntions m~e In the Petition.
10. The defend..nt under.>!tundH thnt. the Protection Order
entered In this matter will be in effect for a period of one year
and can be extended beyond it origin..l expiration date if the
Court finds that the defendant has committed nnother act of abuse
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or has engaged in a pattern or practice that indicates continued
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 ca>!e.
11. Violation of the Protection Order may subject the
defendant to: il arrest under 23 Pa.C.S. ~6113; ii) a private
criminal complaint under 23 Pa.C.S. ~6113.1i iii) a charge of
Indirect criminal contempt under 23 Pa.C.S. ~6114, punishable by
imprisonment up to six months and a fine of $100.00-$1,000.00;
and iv) civil contempt under 23 Pa.C.S. ~6114.1.
12. The defendant and the plaintiff agree to the entry of
an Order providing for the following regarding custody of their
children, Dust.ln bnd Selln Poff.
11, The partie>! shall shllre leglll custody of the
chi ldren.
b. The mother shllll hllve primllry physical custody of
the ch I 1 dren.