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Home My WebLink About97-03252 """', \ ~ ~ , '~ "'\ / / , ! , ~ - CJ ~ V:J ~I t'1 ()" IDA LEE REYES, Plaintiff IN THE COURT OF COMMON PLEAS OF v. CUMBERLAND COUNTY, PENNSYLVANIA NO,97- 3d.5;;>, CIVIL TERM BEVERLY PARDO, Defendant PROTECTION FROM ABUSE TEMPORARY PROTECTION ORDER AND NOW, this n ~ay of June, 1997, upon presentation and consideration of the within Petition, and upon finding that the plaintill: Ida Lee Reyes, now residing at 115 Nonh 2nd Street, I st Floor, Wormleysburg, Cumberland County, Pennsylvania, is in immediate and present danger of abuse from the defendant, Beverly Pardo, the following Temporary Order is entered. The defendant, Beverly Pardo, (SSN: 125-56-7326)(DOB:2/27/61) now residing at 1168 Mulberry Street, Harrisburg, Dauphin County, Pennsylvania, is hereby enjoined from physically abusing the plaintiff, Ida Lee Reyes, or from placing her in fear of abuse. The defendant is ordered to stay away from the plaintill's residence located at 115 Nonh 2nd Street, I st Floor, Wormleysburg, Cumberland County, Pennsylvania, a residence which is leased solely in the name of the plaintiff, and any other residence the plaintiff may in the future establish for herself. The defendant is ordered to refrain from having any direct or indirect contact with the plaintiff including, but not limited to, telephone and written communications. The defendant is enjoined from harassing and stalking the plaintiff and from harassing her relatives, and her minor children. The defendant is enjoined from entering the plaintill's place of employment. ..... Ul ,. fr, [;: -t l-: ~ , w~~~ t)~ ~-? ~, H:.l "-- C)~ " cSt ("";0. I:..!;. :-> [t~ .. r- Oo. '.. " r- :~_ i l.. O' Co a, On or about June II, 1997 the defendant came to the plaintill's residence, littered the yard with harassing and threatening letters that she had written to the plaintiff, which included such threats as "you're dead, and threw clothing belonging to the plaintiff about the yard, The West Shore Regional Police were contacted b. In or about May, 1997, the defendant entered the plaintill's home uninvited while the plaintiff was out. The plaintiff arrived home and the defendant came outside and pushed the plaintiff over a fence, the defendant straddled the plaintiff, punched her in the eye with a closed fist. slapped her face. choked and scratched her. The defendant stopped only when the plaintiffs uncle intervened. The plaintiffs eye was bruised and swollen as a result of the incident. The West Shore Regional Police were contacted. c. In or about May, 1997, the defendant left several harassing messages on the plaintiffs answering machine, threatening to kill the plaintiff or put her in the hospital and funher threatening to hun the plaintiffs children. Fearing for her safety and the safety of her children, the plaintiff reponed the harassing telephone calls to the telephone company and had her phone number changed. d. In or about December, 1996, the defendant became angry and held a butcher knife to the plaintiffs neck as she lay in bed, causing her to fear for her safety. e. On or ahout July 5, 1996, the defendant slapped the plaintiff as she lay in bed, straddled her and pinned her to the bed. When the plaintiff was able to free herself she left the room to avoid funher abuse 5. The plaintiff believes and therefore avers that she is in immediate and present danger of abuse from the defendantand that she is in need of protection from such abuse. 6. The plaintiff desires that the defendant be prohibited from having any direct or indirect contact with the plaintiff her minor children including, but not limited to, telephone and written communications, 7. The plaintiff desires that the defendant be enjoined from harassing and stalking the plaintiff, and from harassing her relatives. and her minor children. 8. The plaintiff desires that the defendant be restrained from entering her place of employment. 9. The plaintiff desires that the defendant be enjoined from removing, damaging, destroying or selling any property owned by the plaintiff. B. EXCLUSIVE POSSESSION 10, The apanment at 115 North 2nd Street, I st Floor, Worrnleysburg, Cumberland County, Pennsylvania, from which the plaintiff is asking the Coun to order the defendant to stay away from, is rented solely in the plaintiffs name. The defendant moved from the plaintiffs home n February, 1997, and has been residing with her sister, Cynthia Pardo, at 1168 Mulberry Street, Harrisburg. Dauphin County, Pennsylvania, C. LOSSES AND REIMBURSEMENT FOR COST OF CASE 11. The plaintiff has suffered losses as a result of the abuse by the defendant. The losses are listed on Exhibit A attached 6, Ordering the defendant to stay away from the plaintifl's residence located on the firstlloor at 115 Nonh 2nd Street, I st Floor, Worrnleysburg, Cumberland County, Pennsylvania, and any other residence the plaintiff may in the future establish for herself. 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: \, Ordering the defendant to refrain 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 and from harassing her relatives and her minor children. 4. Prohibiting the defendant from entering the plaintifl's place of employment. 5. Prohibiting the defendant from removing, damaging, destroying or selling propeny owned by the plaintiff. 6, Ordering the defendant to stay away from the plaintifl's residence located at 115 Nonh 2nd Street, 1 st Floor, Wormleysburg, Cumberland County, Pennsylvania, and any other residence the plaintiff may in the future establish for herself. 7, Ordering the defendant to reimburse the plaintill's out-of-pocket losses suffered as a result of the abuse including but not limited to the losses listed on the attached sheet marked Exhibit A. 8. Ordering the defendant to pay $250,00 to Cumberland County, one of Legal Services, 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 coun costs to the defendant if the case goes to hearing. The plaintiff funher asks that this Petition be filed and served without payment offees and costs by the plaintiff, pending a funher order at the hearing, and that cenified copies of this Petition and Order be delivered to West Shore Regional and Lower Allen Township Police Depanments and any other appropriate police depanments which have jurisdiction to enforce this Order. The plaintiff prays for such other relief as may be just and proper. Respectfully submitted, //'1 --1V lf~Vu.'L-' (. oan 'Carey, Attorney for LEGAL SERVICES, INC. 8 Irvine Row Carlisle. P A 17013 IDA LEE REYES, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO,97- CIVIL TERM BEVERLY PARDO, Defendant : PROTECTION FROM ABUSE OUT-OF-POCKET LOSSES The plaintiff requests that the defendant reimburse her out-of-pocket losses. including but not limited to, the following: The plaintiff has lost wages from her employment as a result of the incidents of abuse as indicated in the Petition for Protection Order, June 12, 1997: I hour June II, 1997: 8 hours June 13, 1997: 4 hours May 20, 1997: 8 hours TOTAL: 21 hoursx$10.10=$212.10 Exhibit A -... ,... '>- f':; c I.. I' : ..:r < tJJ' c' . i- , c.. , .- ( : -. r.' 0 l:.: I I , .. t-. 1"- ; -. C. . ':..J r- \:l- ..... - . ~ -..:I y:, ~ ,., .. ,~ d J. IDA LEE REYES, Plaintiff IN TIlE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 97- 3252 CIVIL TERM PROTECTION FROM ABUSE v. BEVERLY PARDO, Defendant PROTECTION ORDER AND NOW, this 2d... day of June, 1997, upon consideration of the Consent Agreement of the panies, the following Order is entered: I, The defendant, Beverly Pardo, is enjoined from physically abusing the plaintiff, Ida Lee Reyes, 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 the plaintiffs relatives. 4. The defendant is prohibited from entering the plaintiffs place of employment. 5. The defendant is prohibited from removing, damaging, destroying or selling any propeny owned by the plaintill~ 6. The defendant is ordered to stay away from the plaintiffs residence located at I IS Nonh 2nd Street. I st Floor, Wormleysburg, Cumberland County. Pennsylvania, or any other residence the plaintiff may in the future establish for herself 7, The coun costs and fees are waived. 8. This Order shall remain in effect for a period of one year or until funher Order of Coun. The Order can be extended beyond its original expiration date if the Court finds that the defendant has committed an act of abuse or has engaged in ft paJlerl1 or practice t~at indicates risk of harm to the plaintiff. r~L~;)- C"iie=. (. 1._:-' "}i.':1Y " {.'; !l: /2 n"' .' ':"1'" t: : :.~\' . ..1 7. The coun costs and fees are waived. 8, The 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 effect for a period of one year and can be extended beyond it original expiration date if the Coun 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 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, 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. ~61 \3. I; jji) a charge of indirect criminal contempt under 23 Pa.C.S. ~6114. punishable by imprisonment up to six months and a fine of$IOO,OO-$I,OOO.OO; and iv) civil contempt under 23 Pa.C.S. ~6114,1. WHEREFORE, the panies request that a Protection Order be entered to rellectthe above terms, Ida~,= /,/ v- ( I JV~:? . g:.~ 0~ Beverly ardo, /Defendant ~,U\ LEGAL SERVICES. INC. 8 Irvine Row Carlisle. PA 17013 (717) 243-9400