HomeMy WebLinkAbout97-01613
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ANDREA EILEEN DEAVER,
PllIintifi'
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO, 97-1613 CIVIL TERM
DONALD GEORGE RUPP.
Defendant
PROTECTION FROM ABUSE
I J~ PROTECTION ORDER
AND NOW, this IT day of April, 1997, upon cunsideration of the Consent Agreement
of the parties, the following Order is entered:
1. The defendant. Donald George Rupp. is enjoined from physically abusing the
plaintiff, Andrea Eileen Beaver, or from placing her in fear of abuse.
2. The defendant is enjoined from having any direct or indirect contact with the
plaintiff including, but not limited to. telephone and written communications.
3. The defendant is ordered to refrain from harassing and stalking the plaintiff and
from harassing her relatives.
4, The defendant is prohibited from entering the plaintifl's places of employment.
5. The defendant is prohibited from removing, damaging, destroying or selling any
property owned by the plaintiff.
6. The defendant ordered to stay away from the plaintifl's residence located at 209
South Washington Street, Mechanicsburg, Cumberland County, Pennsylvania, and is ordered to
stay away from any residence the plaintiff may in the future establish for herself.
7. The defendant shall reimburse the plaintifl's out-of-pocket losses of $]93.46
sull'cred as a result of the incident on or about March 25, 1997, including, but not limited to. the
losses listed on the attached sheet marked Exhibit A. The defendant shall commence payment of
losses to the plaintiff within five (5) days of the entry of the Protection Order in the above-
captioned matter, payments to be made payable to the plaintiff, by money order, mailed to her
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residence. The total amount of losses shall be reimbursed to the plaintiff within 30 days of the
entry of the Protection Order.
8, Court costs and fees are waived.
9. This Order shall remain in efiect for a period of one (I) year and can be extended
beyond that time if the Court finds that the defendant has com milled an act of abuse or has
engaged in a pall em or practice that indicates risk of harm to the plaintifi~ This Order shall be
enforceable in the same manner as the Court's prior Temporary Protection Order entered in this
case.
10. 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; iii) a charge of indirect criminal contempt
under 23 Pa.C,S, ~6] 14. 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.
II. The Mechanicsburg and Upper Allen Township Police Departments and any other
appropriate police department shall be provided with certified copies of this Order by the
plaintiffs allomey 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
commilled in the presence of the police officer. In the event that an arrest is made under this
section, the defendant shall be taken without unnecessary 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.C.S, 96] 13).
Joan Carey, Allomey for Plaintifi'. . .
Cr'fUiJ... ),\,td'..(
Donald George Rupp. Defendant 1./-11./ - '17 .'d.(.~
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ANDREA EILEEN REAVER,
Plaintill.
IN THE COURT OF COMMON PI.EAS OF
CUMBERLAND COUNTY, I'ENNSYL VANIA
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v,
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NO. 97-1613 CIVIL TERM
DONALD GEORGE RUI'I).
Defendant
PROTECTION FROM ABUSE
CONSENT AGREEMENT
This Agreement is entered on this _9-7!::-- day of April. 1991, by the plaintill: Andrea
Eileen Beavesr, and the defendant, Donald George Rupp. The plaintifl'is represented by Joan
Carey of LEGAL SERVICES, INC.; the defendant is unrepresented but is aware of his right to
have an attorney, The parties agree that the following may be entered as an Order of Court,
I. The defendant, Donald George Rupp, agrees to refrain from abusing the plaintiff,
Andrea Eileen Beaver, or from placing her in fear of abuse.
2. The defendant agrees not to have any direct or indirect contact with the plaintiff
including. but not limited to, telephone and written communications.
3. The defendant agrees not to harass and stalk the plaintill:
4. The defendant agrees not to enter the plaintifl's places of employment.
5, The defendant agrees not to remove, damage, destroy, or sell any property owned
by the plaintiff.
6. The defendant agrees to stay away from the plaintifl's residence located at 209
South Washington Street. Mechanicsburg. Cumberland County. Pennsylvania, and the defendant
agrees to stay away from any residence the plaintiff may in the future establish for herself.
7. The defendant agrees to reimburse the plaintitl's out-ol:pocketlosses of $193.46
suffered as a result of the incident on or about March 25, 1991, including. but not limited to, the
losses listed on the attached sheet marked Exhibit A. The defendant agrees to commence
payment of losses to the plaintiff within live (5) days of the entry of the Protection Order in the
above-captioned matter. payments to be made payable to the plaintiff, by money order. mailed to
her residence. The total amount oflosses shall be reimbursed to the plaintifi' within 30 days of the
entry of the Proteetion Order.
S, Tlur defendant, although entering into this Agreement, does not admit the
allegations made in the Petition,
9, The defendant understands that the Protection Order entered in this matter will be
in elTect for a period of one (I) year and can be extended beyond that time 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 plaintilT. 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.
10. Violation of the Protection 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; iii) a charge of indirect
criminal contempt under 23 Pa.C.S. *6114, punishable by imprisonment up to six months and a
fine of$1 00.00-$ I ,000.00; and iv) civil contempt under 23 Pa.C.S. *6114.1.
WHEREFORE, the parties request that a Protection Order be entered to reflect the above
terms,
~f. 13~
f)~c;(c/C i2r
Donald George Rupp. Defendant
Andrea Eileen Beaver. PlaintilT /
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(JiJan Carey. Attorney for pU6htilT
v
LEGAL SERVICES. INC.
S Irvine Row
Carlisle, P A 17013
(717) 243-9400
ANDREA EILEEN DEAVER,
Plaintitl.
IN TIlE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY,PENNSYLVANIA
v.
NO, 97-161J CIVIL TERM
DONALD GEORGE RUPP,
Defendant
PROTECTION FROM ABUSE
AFFIOA VIT OF SF.RVICE
I, Rodney Whitcomb, do hereby certify that on March 31, 1997, at 4:48 p.m.. 1 did
personally serve upon the defendant. Donald George Rupp, a certified copy of the above-
captioned Temporary Protection Order and Petition for Protection Order on Railroad Avenue,
Mechanicsburg, Cumberland County, Pennsylvania.
MECHANICSBURG POLICE DEPT. ,
, 102 West Allen Street
Mechanicsburg, PA 17055
Telephone: (717) 691-3300
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CERTIFICATION OF BAIL
AND DISCHARGE
POllel r.A~( NO
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OTN
cr '"'"&"0 1997-1613 Civil Te
COMl,lONW(AlTH VS 100'e("(1,.,,/ Nam..fl(JAl;1alllSSI
CHARGllSr
DATlOfOiAIlGCISI
Donald George Rupp
24 Green St.
icsbur PA 17055
G: ROR (no surely) 0 Nom'nalBall
o Ball (lolal amount sel. ,I any) S
D Conditions 01 Release (aSide Irom appearing al court when required:)
Indirect Criminal Contempt
(Violation of Protection from Abuse Order)
NEXT COURT ACTION
DAn MiD III.l[ lOCA'IO~4 Courtrocm #3
June 5, 1997 3:30 P Mr:umberland Co. Courtho
TO 0 Oelenl'on Center 0 Olher
SECURITY OR SURETy Iff ANY I
o Surely Company
o Professional Bondsman
o Really
o Olher
(allach addendum, if necessary)
I hereby cerltly thai sull,clcnl ball has been colored
o By Ihe dolendanl 0 On behall ollhe del end ani by
INiJmfJ& Atldll'SSo/Suletrl ll.cenSflNol
OOR
· Refund 01 cash ball WIll bo made Within 20 days aller
I,nal d'Spo"I'on (Pa R,Cr P 4015(bi)
· Refund of all olher types 01 ball Will be made promplJy aller
20days follOWing final disposition IPa.R.er.p, 4015(a))
. Bring Cash Ball Receipllo Clerk of Courl.
JuDGE OR IssuJ~m AUTHORITY
Ed ar B. Bayley J.
APPEARANCE OR BAIL BOND
THIS BOND IS VALID FOR THE ENTIRE PROCEEDINGS AND
UNTIL FULL AND FINAL DISPOSITION OF THE CASE INCLUDING
FINAL DISPOSITION OF ANY PETITION FOR WRIT OF CERTIORARI
OR APPEAL TIMELY FILED IN THE SUPREME COURT OF THE
UNITED STATES.
DISCHARGE THE ABOVE'NAMED DEfENDANT fROM CUSTODY If
DETAINED fOR NO OTHER CAUSE THAN THE ABOVE STA TED,
Given under mv hand and the Olliclaf Seal ollhis Courl,
19th
Ih!S
May
dayol
,192
(SEAL)
WE, THE UNDERSIGNED, defendanl end aurely, our .ucceuor., heir. and aulgns, are jolnlly and .e.erelly bound to pey 10 Ihe
Commonweellh of Pann.yl.snle the sum of doll..s (S ).
SEE REVERSE SIDE FOR BAIL CONDITIONS
CERTIFICATION OF COUNTER INDEMNITY AND PREMIUM (Applicable Only When Surety IsA Corporal ion)
,PrinCipal. and
hereby certily Ihallhe amounl paid by said PrinCipal 10 said 5U1ely lor bail In the above mailer IS S
and lhal no rUrlher sum Ot sums IS 10 be paid Ihetelore by Ihe said Principal or anyone on hiS behalf.
We further Cerllly Ihal said Pnnclpal has given 10 said Surety counler mdemmly conslsllng 01
ollhe value 01 S
as lollows:
and no lurther counler indemmly is 10 be given Ihe said Surety excepl
W,lurlher Willy Ihatlhere are no Judgmenls agamSllhe saId corporale surely oulSlaMmg and unpaId lor a P,"od 01 more than Ihllly days lrom Ihe dale ollhe enlry 01 such
Judgmenl excepllhose In which a pellllon 10 open or vacate the Judgmenl has been II led and remains undisposed 01
Dated:
.19
MUST BE SIGNED IN PERSON
BY THE APPROVED AGENT
I ACKNOWLEDGE THAT I AM LEGALLY RESPONSIBLE FOR
THE FULL AMOUNT OF THE BAIL,
(f'''''C'{lJlj
(SEAL)
(SEAL)
~"~~ ~ r~~
!,r(,t....TUlll Of IlrIM)A')-~1
(SEAL)
The lollowlng acknowledgement IS also appllcaOle
/I Percentage Cash Ba,f IS used
THIS BOND SIGNED ON Mav 19.
al Carlisle
(SEAL)
SIgnarure 01 Surcty (May be Bondsman, Ba,f Agency, or pflv{J(e
individual or organ/latlon) Except when defendant IS relcased on his
own recognl/ance (ROR), rhls must be signed In all ball SItuations,
Includmg nommal boll/
:J r/ r:::- /( EPJ? S ( IY1. c-f/' 1)d'J[J"
19J!L
PENNSYLVANIA
Signed and aCknowledged berore me Ull5
19th day 01 Mav
,19J!L
Alil,III',',(11 ~,(jlll" ~,llJlI 'tU)I,"'MjtOll[JIII~~nM.1
· In C,1se 0 corpora/C surety ball, Power 01 Attolney must
bo all/xed to Oond or otherWise bond IS mvalld
'"'''''' 1'0" ," l't""'H'Ol',1! 11,1II,'\m.," l'n'rl1" N.) '" "lh',U'''''[I..,t>
OIlIGlr~^L
· In case 01 Percentage Cash Ballor Nomma' Balf, Power
01 Attolney IS not requlfed Aore Ht-82
, Surely,
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tel law, 3ays, thClt. he made 03 dlllgpot ;:;earch .:1nd 1nquIry fc.r t.hr! ....11-.111.0
n;Jm>?d defendant, to wit:
IWPP [1011.\1.[' Gl-:llliGI':
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In The Court of Common Pleas of Cumberland County, Pennsylvania
Andrea Eilecn Beavcr
vs.
Donald Georgc Rupp
No. 97-1613 Civil Term 19_
Now. Mar. 31. 199719_.1 SHERIFF Of CUMBERLAND COUNTY. PA do hereb)' deputize the SherllTof
York County 10 execute Ihls Wrll, Ihls depulallon being made allhe request and risk oflhe Plain lilT.
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SherllT of Cumberland County. Po.
Affidavit of Service
Now,
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by handing to
a"ested copy of Ihe original
Ihe conlents Ihereof.
a Irue and
ond made known 10
So answers.
SherilT of
County, Po.
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COSTS
19_
SERVICE
MILEAGE
AFFIDA VIT
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Sworn and subscribed berore
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INSTRUCTIONS TO THE DEFENDANT
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":;~)'U~~s'y~Uk~~W' , the plaintiff has filed a legal action against you under the protection,'
'F:tQ'liIi,'Allu'seActand has obtained a Temporary Protection Order. The plaintiff Is prepared
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,to;~nYe,'8~earlng held in order to obtain a final Protection Order effective for one (l) year.
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:"~-';;:;;"/As/l-n~ternative, you may consent to the entry of the final protection Order to be in '
~.}~~~~~".J':,ro';;~,___:_.',,:-'r'-_::",'., '.- " '., .' ' . . ., - - . .. . .
t~~~;for,~ne,)'ear. ,If you are willing to consent you should ClIll Legal services" l~c. In .
'lS,.r:~,;:;:~:~::_~_,::_,:::",;,."L::~;:-':,'-: .'. .':, " '.- -,' .' " ' .,
:~flUll~,;~~:243:94001,7~847S from the West Shore orS3D-S866 r~m. Shlppensburg,, andasJC;
;~I;~~f\>~~j~;}/i'\/::~-;'>:'-_:':::'-:, ',-' ,-', ,':',' ." "" '-; '>:~",:.-"
\~1;8~It'tOtl!e stafr person handlin8 the case about a Consent Ag.ccmC:lIl. '
,'1S:D~0,~!:;j',"},\;:>-'-i-';":"'-;_::', c' "'. .' .''- > .-
_~'V,'}>',',TheConsentAgreelT\ent should be prepared before the time scheduled for the hearing;
Lt.:C:'}:~-<'~~'~'~'/; ,>. ::':, ," ..
\S6:ih~Couftwill .know' ahead of time that, the ClIBC will not be contested. In some ClIses,
i;'~~'?:;~?-;..;"~~'t':\'.:;"'..:"',;",,,,_;,,,:, ';,: . -' . .' . _' _ '. '.' , '. .... " _ '. ;'., -
i:~e8#rdiess'ofwhethera settlement by Consent Agreement has been reached, the parties
:~~!t~f~~::~;);:';_::~::}'::-~-;;:_~'.,"~::: '::~::':'.'" -,.-',' _ ' ,'. ' . , '. - ' , . ":
;jU~s~-.a.ppenriricourtat .thetlme'scheduled for hearing. If the case is uncontested, ' the
{~f:0~<;~:::~~tr:;:-_:--,:-.;L~~,,;_>.-->, ':.>,' . , ,
:&l\ift:appea~ance' will be brief. The judge will make sure the parties understand, the, " '
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(CCinsent';'Agreementand final Protection Order.
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li'!,:,:{"If:y_oirl1o .nCltagree to the entry of the final Protection Order, a coritestedhenrlng will
:!:J::;~'~:(i}:~';~'_" ;::_:_",/,:;"::\,",;':.' "",_ -, ::- ;-: . ",' ';,''- . . '
t~~~}~I~e<ll.t ,the ,scheduled, time. When a final Protection Order is entered; it,will be seritor
-:'~_ii"'l'~,:""~'"'_':_'>'_>"""_'--"'~ ,',,-. _ '.. .' ':
tiiiv~n,icl'tou, tile plalntifC, and the appropriate ,police departments. If youCaUto abide by.
::-;~llf)r';(;',:;':',;:, : ",- :): ,.', ",' ~- '. , - ' . -' ' .. - -,'
;{~he~ertns,orthefinal Protection Order you will be subject to Immediate arrest, 'snda fin'e. or-
l:j./r;R,:i:;_",-,':",'-,';;,:.",':--' ".:", . , . : . ,,<:' "-"
:i-~.~o,?:?OtO$l,?OO.OO and/or a jail sentence of up to six months and other relief.
;::;};~'Y/ ,". , , FRES AND COSTS
;;t{':})idhe~ase goes to hearing and the judge grants a protection Order, 1\ surchargeoC
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i:~2S;OO wiU'bellssessed against you. You may also be required to pay attorney Cees to '-egll!
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(;"Seb,lces;tnc. for their representation of the plaintiff.
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,'r. ..; you SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU 00 NOT HAVE A, "
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;);(.WvEk,' OR CANNOT AFFORD ONE, GO TO OR TELEPHONE
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'f1NoOUT,WHEREYOU CAN GET I,EGAL HELP.
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'THE OFFICE
SET FORTH BELOW TO
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COURT ADMINISTRATOR, 4th FLOOR
CUMBERLAND COUNTY COURTHOUSE
CARI.ISI.E. PENNSYLVANIA 17013
TELEPHONE N!.lMl\ER: (717) 240-6200
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ANDREA EILEEN BEAVER.
PlaintilT
IN THE COURT OF COMMON PLEAS OF
v.
CUMBERLAND COUNTY. PENNSYLVANIA
NO.9:?- 91-/&/.3 CIVILTERM
DONALD GEORGE RUPP.
Defendant
PROTECTION FROM ABUSE
TEMPORARY PROTECTION ORDER
AND NOW, this ~ of -=nJWt( h . 1997, upon presentation and consideration
of the within Petition, and upon finding that the plaintiff, Andrea Eileen Beaver. now residing at
209 South Washington Street, Mechanicsburg, Cumberland County, Pennsylvania, is in immediate
and present danger of abuse from the defendant, Donald George Rupp, the following Temporary
Order is entered.
The defendant, Donald George Rupp, (SSN: Unknown)(DOB: 5/24/56), is an adult whose
current address is unknown to the plaintilT. is hereby enjoined from physically abusing the
plaintiff, Andrea Eileen Beaver. or from placing her in fear of abuse.
The defendant is ordered to stay away from the plaintiffs residence located at 209 South
Washington Street, Mechanicsburg, Cumberland County. Pennsylvania, a residence which is
, '
leased by the plaintiff, and is ordered to stay away from any residence the plaintilT may in the
future establish for herself.
The defendant is ordered to relTain from having any direct or indirect contact with the
.plaintilTincluding, but nOllimifed to, telephone and wri,uen communications,
The defendant is enjoined. from harassing and stalking the plain tilT and from harassing her
relatives.
The defendant is enjoined from entering the plaintiffs places of employment.
~,
The defendant is enjoined from removing, damaging, destroying or selling any property
owned by the plaintiff.
A viollltion of this Order mllY subject the defendllnt to: i) lIrrest under 23 PlI.C.S.
~6113; ii) II privllte criminlll complllint under 23 PlI.C.S. ~6113.1; iii) II chllrge of indirect
criminlll contempt under 23 Pa.C.S. ~6114. punishllble hy imprisonment up to six months
and II line ofSIOO.OO-SI,OOO.OO; lInd iv) civil contempt under 23 PlI.C.S. ~6114.1.
This Order shall remain in effect until modified or terminated by the Court and can be
ext(;nded beyond its original expiration date if the Court finds that the defendant has commined an
act of abuse or has engaged in a panem or practice that indicates risk of hann to the plaintiff.
A HEARING SHALL BE HELD ON TillS MA TIER ON CI./Jht ~ 1 ,1997.
AT II. (flJ () .M., IN COURTROOM NO.~, OF THE CUMBERLAND
COUNTY COURTHOUSE, CARLISLE. PENNSYLVANIA.
The plainiiff may proceed without pre-payment of fees pending a further order aner the
hearing.
The Cumberland County Sherifl's Department shall ancmpt to make service at the
plaintifl's request and without pre-payment of fees. but service may be accomplished under any
. ,
applicable rule of Civil Procedure,
. .,
This Orde~ shall b.e docketed in the office of the Prothonotary and fOlwlIrded to the Sheriff
for service. The Prothonotary shall not send a copy of this Order to the defendant by mail,
The Mechani€sburg Police Department shall be provided with a certified copy of this
Order by the plaintifl's anomey. . 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, whcther or not the violation is com mined in the presence
of the police officer, In the event that an arrest is made. under this section, the defendant shall be
taken without unnecessary 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.C.S,
*6113),
By the Coun,
t<- I C~~L "~)( ,c. ~\v(r..'('
Judge
lTllJE'COPY FFlOM HECORD
1'1 '~:',;I:i'lUrIY 'Nt'~rf<:,f. 11'""fG un~o ...~t my haHd
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I'foliloootary
Joan Carey
LEGAL SERVICES, INC.
Attorney for Plaintiff .
,
ANDREA EILEEN BEAVER,
PlaintilT
IN THE COURT OF COMMON PLEAS OF
,
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CUMBERLAND COUNTY. PENNSYLVANIA
v.
NO. 97-
CIVIL TERM
DONALD GEORGE RUPP,
Defendant
PROTECTION FROM ABUSE
NOTICE
You have been sued in coun. If you wish to detend against the claims set tanh 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 Coun and presenting to the
Coun your defenses or objections to the claims set tanh against you. You are warned that if you
fail to do so the Coun may proceed without you. and a judgment m.ay be entered against you by
the Coun without fun her 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 plaintifl~
You should take this paper to your lawyer at once. If you do not have a lawyer or
. cannot afford one, go to or telephone the office set forth below to find out where you can
get legal help.
COuRT ADMINISTRATOR, 4th FLOOR
CUMBERLAND COUNTY COURTHOUSE
. CARLISLE, PENNSYLVANIA 17013
TELEPHONE NUMBER: (717) 240-6200
, .
AMERICANS WITII DISABILITIES ACT OF 1990
The Coun bfCommon 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 coun,
please contact our office. All arrangements must be made at least 72 hours prior to any hearing
or business before the coun.
ANDREA EILEEN BEAVER,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY. PENNSYLVANIA
v.
NO. 97-
CIVIL TERM
DONALD GEORGE RUPP.
Defendant
PROTECTION FROM ABUSE
PETITION FOR PROTECTION ORDER
RELIEF UNDER THE PROTECTION FROM ABUSE
ACT, 23 Pa.C,S, ~6101 et seq.
A. ABUSE
I. The plaintiff, Andrea Eileen Beaver. is an adult individual residing at 209 South
Washington Street, Mechanicsburg, Cumberland County, Pennsylvania 17055.
2. The defendant, Donald George Rupp, (SSN: Unknown)(DOB: 5/24/56), is an
adult whose current address is unknown to the plaintiff.
3. The defendant has had an intimate relationship with the plaintiff.
4. Since approximately 1993, 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~ has knowingly engaged in a course of
conduct or r~peatedly committed acts toward th~ plaintiff under circumstances which have placed
her in reasonable fear of bodily injury. This has included. but is not limited to, the following
specific instances of abuse: .
a) On or about March 25, 1997,' the defendani yelled and shouted at the
plaintiff, . pushed and shoved her about. slammed her against the refrigerator
cau~ing her to hit her head and fall to the floor, crouched over her as she lay on the.
floor, held his fist in her face, and threatened her saying, "I want to bash your face
in." When the plaintiff got away from the defendant and asked him to leave, he
refused. As the plaintiff tried to leave her home, the defendant grabbed her by the
arm, shoved her out the door, and locked it. The plaintiff went to the
Mechanicsburg Police Department and requested that they remove the defcndant
from her homc, which thcy did. Thc plaintiff sustaincd sorcncss about her head,
brokcn blood vesscls in her cyc, and headaches as a rcsult of this incident and
sought mcdical trcatment for her injurics.
b) In or about late February or carly March, 1997, when the plaintiff len
work, shc saw thc defendant sitting in his truck parkcd ncxt to hcr car in the
parking lot of hcr work. When she len work, he followed her to hcr home
causing her to fea~ for her safety.
c) Since approximately 1993. the dcfcndant has abused the plaintiff in ways
including, but not Iimitcd to, pushing and shoving her about, punching, kicking,
and choking her, following her about in his vehicle, waiting for her at her home
when she returns from work at night, harassing her by tclcphoning her home
.repeatedly in the early hours of the morning keeping her from sleeping, and
threatening her on sevcral occasions with bodily harm. Thc plaintiff fcars for her
safety.
5. The plaintiff believes and thercforc avers that she is in immediate and prescnt
danger of abuse frpm the .delendant and is in necd of protection from such abuse.
6. The plaintiff desircstbat' the defcndant be prohibited from having any direct or
,indirect contact with the plaintiff includi"ng, but ,not limited .to, telcphone and written
communications.
7.
plaintiff.
8.
employment.
The plaintiff desircs that thc defcndant be enjoined from harassing and stalking the.
The plaintiff dcsircs that thc dcfcndant be restrained trom cntcring her places of
9. Thc plaintiff desircs that thc defcndant be enjoined from removing, damaging,
destroying or selling any property owned by the plaintiff.
B. EXCL.USIVE POSSESSION
10. Thc home from which thc plaintiff is asking the Court to order the defendant to
stay away from is rcnted in the name of Andrca Eilcen Beaver.
C. LOSSES AND REIMBURSEMENT FOR COST OF CASE
II. The plaintiff has suffcred losses as a rcsult of thc abuse by the dcfendant. Thc
losses are listed on Exhibit A attached,
12. Ordering the defendant to pay $250.00 to Cumberland County, one of Legal
Serviccs, Inc.'s funding sources, in lieu of attorneys' fees, as reimbursement for the cost of
litigating this case and assessing the $25.00 surcharge and court costs to the defendant if the case
goes to hearing.
WHEREFORE, pursuant to the provisions of the "Protection from Abuse Act" of October
7, 1976,23 P.S. 96101 ct gm., as amended, thc plaintiff prays this Honorable Court to grant the
following relief:
A. Grant a Temporary Order pur~uant to the ."Protcction from Abuse Act:"
I. Ordering thc defendant to refrain from abusing the plaintiff or from
placing her in fear of abuse.
2. Ordering the defendant to rcfrain from having any dircct or indircct
.contact with the plairitiff including, but not limited to. telephone and
written communications.
3. Ordering the defendant to rcfrain from harassing and stalking the.
plaintiff.
4. Prohibiting the defcndant from entering thc plaintiffs places of
cmployment.
5, Prohibiting thc defcndant from removing, damaging, dcstroying or
selling property owncd by the plaintiff.
6, Ordering the defcndant to stay away from thc plaint ill's residencc
located at 209 South Washington Street, Mcchanicsburg, Cumbcrland
County, Pennsylvania, and ordering the defendant to stay away from any
rcsidence the plaintiff may in the future establish for herself.
B. Schedule a hcaring in accordancc with the provisions of the "Protection from
Abuse Act," and, aner such hearing, enter an order to bc in clTect for a period of one year:
\, Ordering the defendant to rcfrain from abusing the plaintiff or from
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.
4, Prohibiting the defen~ant from entering the plaintill's places of
employment.
"
5. Prohibiting the defendant from removing, damaging, destroying or
selling property jointly owned by the plaintiff.
.6. Ordering the defendant to stay away from the plaintiffs residence
located at. 209 South Washington Street. Mcchanicsburg, Cumberland
County, Pennsylvl\nia, and ordcring the defendant to stay away from any.
residence the plaintiff may in the futurc establish for herself.
I
!
"
7, Ordering the dcfendant to reimburse the plaintiffs out-of-pocket
losses suffered as a result of the abuse including but not limited to the
losses listed on thc attached sheet marked Exhibit A.
8. Ordcring the defendant to pay $250,00 to Cumberland County, one
i
I
II
of Legal Services, Inc.'s funding sources, in lieu of attorneys' fees, as
reimbursement for the cost of litigating this casc and assessing the $25,00
surcharge and court costs to the defendant ifthe case goes to hearing,
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 certificd copy of this
Petition and Order be delivcred to the Mechanicsburg Police Department and any other
appropriate policc department which has jurisdiction to enforcc this Order.
The plaintiff prays lor such other relief as may be just and proper.
Respectfully submittcd,
'tt-'IJ~tr..c.~
Jmin Carey, Attorne): or Plaintiff
LEGAL SERVICES. INC.
8 Irvine Row
Carlisle, PA 17013
(717) 243-9400
ANDREA EILEEN BEAVER,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 97-
CIVIL TERM
DONALD GEORGE RUPP,
Defendant
: PROTECTION FROM ABUSE
OUT-OF-POCKET LOSSES
The plaintiff requests that the defendant reimburse her out-of-pocket losses including, but
not limitcd to, the following:
Lost wages from employment as a result of the abusc incident on or about March 25, 1997:
TOTAL
$85,33
$54,08
554.08
5193.49
,.
March 25, 1997 (13 hours)
March 26, 1997 (8 hours)
March 27, 1997 (8 hours)
, .
EXHIBIT A
ANDREA EILEEN BEAVER.
Plaintill'
IN TilE COURT OF COMMON PLEAS OF
v.
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 97-_L~J3___._ CIVIL TERM
DONALD GEORGE RUPP,
Defcndant
PROTECTION FROM ABUSE
TEMPORARY PROTECTION ORDER
AND NOW, this JL1 of '\ or, I, l..(lJ , 1997, upon presentation and consideration
I
of thc within Pctition, and upon finding that the plaintill: Andrca Eileen Beaver, now rcsiding at
209 South Washington Strcct, Mechanicsburg, Cumberland County, Pennsylvania, is in immediatc
and prcscnt dangcr of abuse from the dctendant, Donald George Rupp, thc following Temporary
Ordcr is cntercd.
Thc dcfcndant, Donald Georgc Rupp, (SSN: Unknown)(DOB: 5/24/56), is an adult whosc
current addrcss is unknown to thc plaintin: is hercby cnjoincd from physically abusing the
plaintil\: Andrca Eileen Bcaver, or from placing her in fcar of abusc.
The defcndant is ordercd to stay away from thc plaintill's residencc locatcd at 209 South
Washington Street, Mcchanicsburg, ClImberland County, Pcnnsylvania, a residence which is
leased by the plaintiff, and is ordcrcd to stay away from any residencc the plaintiff may in the
future cstablish for hersclf.
Thc defcndant is ordercd to rcfrain from having any dircct or indircct contact with thc
plaintiff including, but not limited to, telcphonc and written communications.
The defcndant is cnjoincd from harassing and stalking thc plaintin' and from harassing hcr
relativcs.
Thc dcfcndant is cnjoined from cntcring the plaintin's places of employment.
The defcndant is cnjoincd lrom rcmoving, damaging, dcstroying or selling any property
owned by the plaintiff.
A violation of this Order mllY subject the defendnnt to: i) arrest under 23 PII.C.S,
~6113; ii) II private criminlll complnint undcr 23 l'n.C.S, ~6113,1; iii) n chllrge of indirect
criminal contempt under 23 Pn.C.S. ~6t14, punishllhle by imprisonment up to six months
and II fine of 5100.00-$1,000.00; nnd iv) civil contempt under 23 PII,C,S. ~6114.1.
This Order shall rcmain in cfiect until modificd or tcrminatcd by the Court and can bc
extended bcyond its original expiration date if the Court finds that thc defendant has committed an
act of abuse or has cngaged in a pattern or practicc that indicatcs risk of harm to thc plaintiff.
1 0' '7
A HEARING SHAL.L BE HELD ON TillS MATI'ER ON .I f'Il' II I ' 1997,
AT _ ./1;' Of) A.M"IN COURTROOM NO......i...., OF TIlE CUMBERL.AND
COUNTY COURTHOUSE, CARLlSL.E, PENNSYLVANIA.
The plaintiff may procced without prc-paymcnt of fecs pending a further order aner the
hearing.
The Cumberland County Shcrill's Department shall allempt to make scrvicc at the
plaint ill's rcquest and without pre-payment of fces, but servicc may bc accomplished under any
applicable rule of Civil Proccdurc.
This Ordcr shall bc docketed in the office ofthc Prothonotary and forwarded to the Sheriff
for servicc. Thc Prothonotary shall not send a copy of this Order to the dcfendant by mail.
The Mcchanicsburg Policc Dcpartment shall bc provided with a certificd copy of this
Order by the plaintill's attorney. This Order shall be cnforccd by any laIV enforcement agency
where a violation occurs by arrest for indircct criminal contempt without warrant upon probable
causc that this Order has been violated, whethcr or not thc violation is committcd in the prcsence
of the policc officcr. In the cvcnt that an arrcst is made, under this scction, the dcfcndant shall be
taken without unnecessary dclay bcforc the court that issucd the order. Whcn that court is
unavailable, thc defendant shall be taken bcfore thc appropriatc district justice. (23 Pa.CoS.
~6113).
.
Joan Carcy
LEGAL SERVICES, INC.
Attorney for Plaintiff
ANDREA EILEEN BEAVER,
Plaintifi"
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 97- //..13
CIVIL TERM
DONALD GEORGE RUPP,
Defendant
PROTECTION FROM ABUSE
PETITION FOR PROTECTION ORDER
RELlEF UNDER TilE PROTECTION FROM ABUSE
ACT, 23 Pa.C.S. ~6101 et seq.
A, ABUSE
I. Thc plaintiff, Andrea Eilcen Beavcr, is an adult individual residing at 209 South
Washington Strcct, Mechanicsburg, Cumberland County, Pcnnsylvania 17055.
2. Thc dcfcndant, Donald George Rupp, (SSN: Unknown)(DOB: 5/24/56), is an
adult whose currcnt address is unknown to thc plaintiff.
3. The defcndant has had an intimate rclationship with the plaintiff.
4. Since approximately 1993, thc defendant has attempted to cause and has
intentionally, knowingly, or rccklcssly caused bodily injury to thc plaintiff, has placcd thc plaintiff
in rcasonable fear of imminent serious bodily injury, has knowingly engaged in a course of
conduct or repcatcdly committcd acts toward thc plaintiff under circumstanccs which have placcd
her in reasonablc fear of bodily injury, This has includcd, but is not limitcd to, thc following
specific instanccs of abusc:
a) On or about March 25, 1997, thc defendant yclled and shouted at the
plaintiff, pushed and shovcd hcr about, slammcd her against thc refrigerator
causing her to hit hcr hcad and fall to thc floor, crouched ovcr her as shc lay on thc
floor, held his fist in her face, and threatened her saying, "I want to bash your facc
in." When thc plaintiff got away from the dcfendant and asked him to leavc, hc
rcfuscd. As the plaint ill' tried to leave her homc, the dcfcndant grabbcd her by thc
arm, shoved hcr out the door, IInd lockcd it. The plaintifl' wcnt to the
Mechanicsburg Policc Departmcnt and rcquestcd that they removc thc dcfcndant
from hcr homc, which they did. Thc plaintitl'sustained sorcncss about hcr head,
brokcn blood vcssels in her cyc, and headaches as a result of this incidcnt and
sought mcdical trcatment lor hcr injuries.
b) In or about latc February or carly March, 1997, whcn the plaintiff Icft
work, she saw thc dcfcndant sitting in his truck park cd ncxt to hcr car in the
parking lot of her work. When shc Ictl work, he followed her to hcr homc
causing her to fcar for her safcty.
c) Sincc approximately 1993, thc dcfendant has abuscd thc plaintiff in ways
including, but not limitcd to, pushing and shoving her about, punching, kicking,
and choking her, following her about ill his vchicle, waiting for her at hcr home
whcn she rcturns from work at night, harassing her by tclcphoning hcr homc
rcpeatcdly in the carly hours of the morning kceping her from slecping, and
thrcatening her on several occasions with bodily harm. Thc plaintiff fears for her
safety.
5. The plaintiff believcs and thercfore avers that shc is in immcdiate and present
danger of abusc from the dcfendant and is in nccd of protection from such abuse.
6. The plair.tiff dcsircs that the defcndant bc prohibitcd from having any direct or
indircct contact with the plaintifi' including, but not limitcd to, telephonc and wriuen
communications.
7.
plaintit1:
8.
The plaintifi'desires that thc dcfcndant be cnjoincd from harassing and stalking thc
The plaintiff dcsircs that the dclendant be rcstrained lrom entering her placcs of
employmcnt.
90 The plaintiff desires that thc defcndant bc enjoined from rcmoving, damaging,
destroying or sclling any property owncd by thc plaintiff.
8. EXCLUSIVE POSSESSION
10. Thc home from which the plaintifi'is asking thc Court to order thc defendant to
stay away from is rcnted in thc namc of Andrca Eileen Bcavcr.
C. LOSSES AND REIM81JRSEI\1ENT FOR COST OF CASE
II. The plaintiff has suffcrcd losses as a rcsult of thc abusc by thc defcndant. Thc
losses arc listcd on Exhibit A attached.
12. Ordering the dcfendant to pay $250.00 to Cumberland County, onc of Lcgal
Serviccs, Inc.'s funding sourccs, in lieu of attorneys' fecs, as reimbllrsement for the cost of
litigating this casc and asscssing thc $25.00 surchargc and court costs to thc dcfendant if the case
goes to hearing.
WHEREFORE, pursuant to the provisions of the "Protection from Abuse Act" ofOctobcr
7,1976,23 PoS. 96101 et ~., as amended, thc plaintiff prays this Honorablc Court to grant the
following relief:
A. Grant a Temporary Order pursuant to the "Protection Irom Abuse Act:"
I. Ordering the defendant to refrain lrom abusing the plaintiff or from
placing her in fcar of abuse.
2. Ordcring the dcfendant to refrain from having any direct or indirect
contact with thc plaintifi' including, but not limited to, telcphonc and
written communications.
3. Ordcring the defcndant to refrain from harassing and stalking the
plaintiff.
4. Prohibiting the defcndant Irom entering the plaintifi's places of
employment.
50 Prohibiting the defcndant from rcmoving, damaging, dcstroying or
sclling propcrty owned by thc plaintil1~
6. Ordering the defcndant to stay away Irom the plaintill's rcsidencc
located at 209 South Washington Street, Mcchanicsburg, Cumbcrland
County, Pcnnsylvania, and ordering the dcfendant to stay away from any
rcsidencc thc plaintifi' may in thc futurc cstablish lor hcrself.
B. Schedule a hcaring in accordancc with the provisions of thc "Protcction from
Abuse Act," and, ancr such hearing, entcr an order to be in cllect for a pcriod of onc ycar:
I. Ordering thc defcndant to rcfrain Irom abusing thc plaintiff or from
placing her in fear of abuse.
2. Ordcring the dcfendant to rcfrain from having any dircct or indirect
contact with thc plaintiff including, but not limited to, telcphone and
writtcn communications.
3. Ordcring the dcfcndant to refrain from harassing and stalking thc
plaintil1~
4. Prohibiting thc dcfcndant from entcring the plaintill's places of
employment.
50 Prohibiting the defcndant from rcmoving, damaging, destroying or
sclling property jointly owncd by the plaintil1~
6. Ordcring the delendant to stay away from the plaintifi's rcsidcnce
located at 209 South Washington Strcct, Mcchanicsburg, Cumbcrland
County, Pcnnsylvania, and ordering thc delendant 10 stay away from any
rcsidencc the plaintilr may in thc luture cstablish I<Jr herself.
ANDREA EILEEN BEAVER,
Plaintill'
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 97-
CIVIL TERM
DONALD GEORGE RUPP,
Defcndant
PROTECTION FROM ABUSE
OUT-OF-POCKET LOSSES
The plaintiff requcsts that thc dcfendant rcimbursc hcr out-of-pockct losses including, but
not limited to, the following:
Lost wages from cmployment as a rcsult of the abuse incidcnt on or about March 25, 1997: ~
March 25, 1997 (13 hours)
March 26, 1997 (8 hours)
March 27, 1997 (8 hours)
TOTAL
$85.33
$54,08
$54.08
5193.49
EXIIlB1T A
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VS
DONALD GEORGE RUPP.
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
97-1613 CIVIL TERM
PROTECTION FROM ABUSE
J
ANDREA EILEEN BEAVER.
Plainti ff
! I
,I
IN RE: lNlllRECLCRllllN8LUlNIEMPJ/.BAIL
llRDElUILUlU RT
AND NOW. June 5. 1997. 3:45 p,m,. the defendant having
appeared together with the Public Defender. William G. Braught.
Esquire. on a petition alleging him to be in contempt of our
Order of April 14. 1997. the defendant has admitted that he is
in contempt of that Order in that he did violate paragraph 6 by
going to the residence,
The District Attorney having recommended a specific
sentence in the case. to which the victim agrees. the Court does
adopt that sentence and we direct that the defendant shall be
placed on probation for a period of six months on the condition
that he be and remain on good behavior and that he undergo an
alcohol evaluation and complY with the suggestions flowing from
that evaluation. inclUding obtaining treatment if recommended,
It has been related to the Court that the defendant
will be obtaining an evaluation in conjunction with a Driving
Under the Influence charge currentlY pending. A COpy of this
Order shall be sent to the Probation Officer handling his
Driving Under the Influence case, with directions to supervise
the six month probation sentence given in this case,
The victim having appeared in open court and having
requested a modification of the Order entered April 14. 1997. we
do modify that Order in respect to paragraph 2 only. The
ANDREA EILEEN BEAVER,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
V.
DONALD GEORGE RUPP,
Defendant
NO. 97-1613 CIVIL TERM
IN RE: INDIRECT CRIMINAL CONTEMPT
QEnER~~UBI
AND NOW. this 27th day of January. 1998.
defendant having appeared at 97-1613 Civil Term on a petition
alleging that he is in indirect criminal contempt of a
protection from abuse order entered on April 14. 1997. and
defendant admitting he is in violation of the terms and
conditions of that order, he is adjudicated in violation of the
terms and conditions of that order.
Sentence is that defendant undergo a period of
supervised probation for six months concurrent to any other
periods of probation currently being served during which he
shall be and remain on good behavior and comply with all written
instructions of his probation officer and undertake any
treatment recommended pursuant to a previous evaluation that has
been conducted. Defendant is released from commitment.
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