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Home My WebLink About97-03875 '~ ~ c8, , 1 i . 1 ;;PI I , ~ '", J ~. - .- <.3 ~ rt) S/ , JULIE MARIE PENNA Y. Plainlilf IN TilE COURT OF COMMON PLEAS OF v CUMBERLAND COUNTY. PENNSYLVANIA NO 97- ~_~}'i .. CIVIL TERM RAYMOND LEWIS BOYD, Defendant PROTErTIO:-': FROM ABUSE TEMPORARY PROTECTION ORDER AND NOW, this ~ay of ~ ~ ~7 ~ upon presentation and consideration of the within .. Petition. and upon finding that the plaintitl: Julie Marie Pennay. now residing at Valley Ridge Apartments, 371 Claremont Drive. Apt I. Carlisle, Cumberland County. Pennsylvania. is in immediate and present danger of abuse from the defendant. Raymond Lewis Boyd. the following Temporary Order is entered The defendant. Raymond Lewis Boyd. (SSNunknown)(DOB.03/20/521 now residing at 123 South 3rd Street. Sunbury, Northumberland County. Pennsylvania. is hereby enjoined from physically abusing the plaintiff. Julie Marie Pennay, or placing her in fear of abuse The defendant is ordered to stay away from the plaintiffs residence located at Valley Ridge Apanments. 371 Claremont Dri\e. Apt I. Carlisle. Cumberland County. Pennsyh'&llia. a residence which is leased in the name of the plaintiff. Julie Marie Pennay. which is not owned or leased by the defendant. and any other residence the plaintiff may in the future establish for herself The defendant is ordered to retrain lrom hav ill!! an\' dirl!\:t or Indirl!\:t ~-ontact with the plaintiff including, but not limited to. telephone and \\onnen communications The defendant is enjoined from harassing and slalkill!! thl:' plaintiff and from harwing her relatl\ ~'S Thl:' defCndant is enjI.vined lh)fl\ ~erintl the plaintiffs pI4\~ of ~mettI The defendanl is enjoined from removing. damaging. destroying or selling any property owned by the plaintiff A violation of this Order may subjcctthe defendant to: i) arrest under 23 PaeS, ~6113; ii) a private criminal complaint under 23 PaCS ~61131; iii) a charge of indirect criminal contempt under 23 Pa.CS. ~6114. punishable by imprisonment up to six months and a line of $10000-$1.00000; and iv) civil contempt under 23 PaCS, ~6114,1, This Order shall remain in effect until modilied or terminated by the Court and can be extended beyond its original expiration date if the Court linds that the defendant has committed another act of abuse or has engaged in a pallem or practice that indicates continued risk of harm to the plaintiff A HEARING SIIALL BE IIELD ON TillS MATTER ON TIlE. ~')' I.tDAY OF JUL\', 1997, AT{f( I).M.,IN COURTROOM NO.':: ClIMBERLAND COUNTI' COURTHOlISE, CARLISLE, PENNSYLVANIA. The plaintiff may proceed without pre.payment offees pending limher order of court. The Cumberland County Sheriff's Department shall attempt to make sen.ice at the plaintiff's request and without pre-payment of fees. but sen.'ice may be accomplished under any applicable rule of('jvil Procedure This Order shall be docketed in the ollice of the Prothonotary and forwarded to the Sheriff for sen.i<:e The Prothonotary shall not send a copy of this Order to the defendant by mail. The M~ Township Police Departments will be provided with a cenilied copy of this Order by the plaintiff's all~ This Order shall be enfurced by any law enforcement qtnCy wheff a violation occurs by arrest for indirect criminal contempt without warrant upon ptobable cause that this Order hu been violated whtlhtr or 1l(1Ithe violation is comrnit1ed in the JlC~'" of the: police ot1icer In the C'\'tnl that an arm.t is made under this tCI."Iion, the defendant sW be taken without 1lIlM'<:~ dday before the W\lrt that iswed the tl!'da JULIE MARIE PENNA Y. Plaintil1. IN TIlE COlIRT OF COMMON I'LEAS OF CUMBERLAND COUNTY. PENNSYLVANIA v, NO, 1)7- CIVIL TERM RAYMOND LEWIS BOYD. Defendant PROTECTION FROM ABUSE NOTICE You have been sued in eoun, If you wish to defend against the claims set fonh in the follo\\ing 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 fonh against you You are warned that if you fail to do so the Coun may proceed without you. and a judgment may be entered against you by the Coun without funher notice for any money claimed in the Petition or for any other claim or reliefrequcsted by the plaintilT You may lose money or propeny or other rights imponant to you fEES A)I!lH:QSlS If the case goes to hearing and the judge grants a Protection Order. a surcharge of 52500 y,ill be assessed against you You may also be required to pay attorney fees to Legal Scnices. Inc for their representation of the plaintiff You should take this paper to your lawyer at once If you do not have a lay,)'CI or cannot alTord one. go to or telephone the office set fonh below to find out y,here you can get legal help COURT ADMINISTRATOR. 4th FLOOR CUMBERLAND COUNTY COURTHOUSE C ARlIStE. PEN1'oiSYl.\'ANIA 17013 TELEPUONE 1"t:\18ER (717) 240-6200 A~U;RJ[A."i.~.\HJH mSAUl1lnj;S.AUJJLl~ The Coun ofConunon PIa, of Cumberland Counl)' is required by law to comply y,ith the Americans \\ith ()isabilities Act of IQQO For information about accessibk fM:ilities and ~ k'C\ll11RlOdatios anilab1t to disabkd indi\iduals having butli~ beli>re the roun. pIftw contact our ~ All arrangements mu$! be milk II least 72 houn ,,",x 10 II1\' hearing Of bu~s ~ thl: ~"'JUn You must attend the scheduled c~ or haril1tt JULIE MARIE PENNA Y. PlaintifT IN TIlE COURT OF COl\1MON I'LEAS OF ClJl\lIIERLANI> COUNTY. I'ENNSYL VANIA v. NO '17. ('I\'IL TERM RAYMOND LEWIS nOYD. Defendant I'RO lion ION I'ROM ABUSE PETITION "'OR PROTECTION ORDER RELIEF lINDt:R TIn: I'Ron:CflON .'ROM "OIlS.: Acr. 2J P..<'.S. * 6101 rt 'fll. A. AI~I:st I, The plaintilT. Julie Mane 1','Ona\., 1\ an adult II1dl\idllal residing at Valley Ridge Apanments. 371 Claremont l>ri\l\ t\pt I. ('alh\lt', ('umhetland County, I'ennsyhania. 17013, 2 The defendant, Ra\mond 1.\;'\\1) U(,,(t 15S"" lInkoownl (OOB 03120/52). is an adult individual residing at 121 South lrd SUee1, Sunburv. NOl1humberland County, Pennsylvania. 1780 1 3, The defendanl has had an rntimate rC'laIKlI1~lr "ilh the rlaintifT 4 Since appnmmaltlv No\enlbn "1'1', the defendant has placed the plaintift'in reasonable fear of imminent sernlll\ h\>dlh intull, h", knowintdv engaged in a course of conduct or repeatedly committed ach \{)ward lhe rlarntitr undrc (tr~'Um!l\ances which ha\'C placed the plaintifT in reasonable lear oJ'l"tdll\ mJlU\ Thl\ ha, Inclutkxl, but is not limited to. the foDowing specifIC instatten or abuw al UII (It abtlUl Jlth U, I ,,,,n, I"," dd'cndant repeatedly tdtphoned t"," rlamtllT hul\ll "I' and Iet\ ~~ on her aa,,~ering machine asking that she ,'l\llla(t him \'lIU'lUllllwt It) teal thf her !oAtn} hi t)ft (w .'1" Juh \2, 19'17, the ddCndant. in t"," plt..w:e of the plaintiff. Itwutflltld ft, kllllwt ret laNtrt \l\irItL -flI snap )()Ul' fiIding ned. in t\W, I'll ..ill you" The defendant then called the plaintiff humiliating names and threatened her saying, "I had better leave before I kill you tonight. too" The plaintiff feared for her safety, The defendant grabbed the plaintitl's pet cat. saying. "I'm taking him (the cat)," and lell with the animal, The plaintilfdialed 911 for help. and the police came to her residence. but the defendant had lell c) In or about March IQQ7. when the plaintiff told the defendant that she no longer wanted to continue with their relationship. he threatened her saying, "If I see you with another man. I'll blow him a\\iay" The plaintiff feared for her safety d) In or about Fall 19%. the defendant. uninvited by the plaintiff, came to the building where she resides. threatened to "bust her face in" if she was seeing another man. and threatened to kill her The plaintiff feared for her safety e) In or about late December 1995 or early January 1996. the defendant told the plaintiff that he had planned to put explosives in a car and use it to blo\\i up the residence where the plaintiff had been staying The plaintiff feared for her safety f) Since approximately So\ember 1995. \\ihen the plaintilfs 1994 Protection From Abuse Order lapsed (Dauphin County Docket No 4198 S 1994 registered in Cumberland County) the defendant has abused her in ",ays induding. but not limited to. harassing her. threatening her with abuse. threatening to kill her. intimidating her. and threatening to liU her pel animals. and guing through her dresstr drawers and pune taking pmonaI items including items she carmd fur her protedion p.) In or about I <nlll and 1ft I Qq(t the plaintiff fih:\! pmt~'1ion from abuse pctltKlM apJml the- ~ and pt\""'"....." \,.." "'efl1 entered in l.yroming t.~. Pftlns,h_, \\1\ her ~ lhe plal1'lhtl's Idr of abuse i\ e-ucertIated hn:3I.lse llf the .fefllllnrs hBtuo l',f atluw ...llKh \nctudal oot is "''It hmited to. the lllllowing threatening to kill the plaintifl. and himself: holding razor blades and knives to her throat. choking her. kicking her in the head causing a concussion, repealedly punching and slapping her. harassing her, stalking her, and abusing her pets 5, The plaintiff' believes and therelore avers that she is in immediate and present danger of abuse from the defendant and that she is in need of protection from such abuse, 6 The plaintil1" desires that the defendant be prohibited from having any direct or indirect contact with tbe plaintil1" including. but not limited to. telephone and wrillen communications 7 The plaintiff desires that tbe defendant be enjoined from harassing and stalking the plaintiil: and from harassing ber relatives 8 The plaintil1" desires that the detendant be restrained from entering her place of employment 9 The plaintil1" desires that tbe defendant be enjoined from remO\;ng. damaging. destroying or selling any property 0\\ ned by her B. EXnrSI\"t: POSS[SSI()~ 10 The apartment which the plaintilf is asling the ('oun to order the defendant to Slay away from is rented in the name of the plainliff. Julie Marie Pennay. and the defendant has nn'Cf resided there II The defendant has r~ed al I~l South trd Street. Sunbul). ~ol1humberland ("ounty'. Pmnsychania. M""~ appro,imatelv SPOil!( I Q<), ('. 8El~U~l!KSE\l[~l FOR rOST OF (',\St: f2 rhe pJamtllT \ko;ires that lhe (','Ufl (lflkt the dd~ to pas S2~ 00 to ("umbcflAnd (\lUI\t\, OM of l~ ~\l(a 11l\;" ~ 'OOOf\"n, In IIlN of atl\V1W'\'s' tm. as reimbursement for the cost of Ii ligating Ihis case and assess a $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 Pa,C.S ~ 6101 et!iC;!). as amended. the plaintiff prays this Honorable Court to grant Ihe lallowing relief A. Grant a Temporary Order pursuant to the "Protection from Abuse Act:" I, Ordering the defendant to refrain !Tom abusing the plaintiff and !Tom placing her in fear of abuse 2 Ordering the defendant to refrain from having any direct or indirect contact \\ith the plaintiff including. but not limited to. telephone and written communications 3 Ordering the defendant to refrain !Tom harassing and stalking the plaintiff and from harassing her relatives 4 Prohibiting the defendant !Tom entering the plaintiffs place of employment 5 Prohibiting the defendant !Tom remo\ ing. damaging. destroying or selling property O\\ned by the p1aintilT 6 Ordering the defendant to slay away from the plaint ill's resideni% located at Valley Ridge Apartments. HI Claremont Orin. Apt I. Carlisle. Cumberland C'ount)'. Pennsylvania. "hich the parties have ne\er shared. and from any ocher rnideta the plaintiff ma\ in the future establish for hmelf 8 SdIeduk a heari"ll m Bn'\ll'dalk~ "ith the pf\l\ NOM of the .Protect.on tium Abuse Act.. and. after such hearing. enter an order t\\ be m dTel.1 for a periud of (1M year ~ the ddCndant to rdtl1ft !Tom ahu-, the plaiNitT II'ld tnllft ~herlllfurof" 2, Ordering the defendant to retrain from having any direct or indirect contact with the plaintiff including. but not limited to. telephone and wrillen communications, 3, Ordering the defendant to refrain from harassing and stalking the plaintiff and from harassing her relat ives 4, Prohibiting the defendant from entering the plaintill's place of employment 5, Prohibiting the defendant from remo\lng. damaging. destroying or selling property owned by the plaintiff 6 Ordering the defendant to stay away from the plaint ill's residence located at Valley Ridge Apartments. 371 Claremont Drive. Apt. I. Carlisle. Cumberland County. Pennsyh'ania. which the parties have never shared. and from any other residence the plaintiff may in the future establish for herself 7. Ordering the defendant to pay S25000 to Cumberland County. one of legal Sef"\ices. Inc's funding sources. in lieu of atto~'S' fees. as reimbursement for the cost of litigating this case and assessing the S2500 surcharge and COlIn costs to the defendant if the 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 cenifled copy of this Petition and Order be deli\-ered to the Middlese, Township Police Department which has jurisdiction to enforce this Order The plaintiff prays for such other relief as may be just and proper, Respectfully submitted, /') (' ,! ,'J~~~~, .,~/,,' r Philip C Briganti ' Attorneys for Plaintiff LEGAL SERVICES, INC. 8 Irvine Row Carlisle, PA 17013 .. b=J ~ ... "'f ., ,., ." ...1 () ~ I G;'" ,:~ j ,,' ;;1 . .."1 r . ~ )?; - .- . . ) -''1 " - .!('i ell , ," ~yn . i.J ' . ,-4 :"<. :." :~j Ut tr\ ... C- O t ~ ~ ~ ~. "\1 --.. ~ ""-- V f) X (' ~ *- ~ ^'- ~ . - "'.:': . . . . ',. . "r.'.': :.:. :':"'; /'::""::'::"::"; .~\:{ ~~::,:: jl::;::;,),; :::>' :':,~::.X::.~.;::r?:!"';:.:y::,:/)(';" :~~. . .':. OFFICE OF THE SHERIFF OF t;~lO~ COv~n Xo. 3875 . Le"i'b..". P.. July 21 R. THOMAS KLINE, SI/ERIFF 97 Tn=. If__ 97 If_ ...... Dur Sin I" ~o I:Iri.r cl JULIE HARlE PENNAY "Ir'~. RAYHOND LEWIS BOYD ~o -">i. bu b.." rtcll"ld Ccrt. 21.00 lIijlC" ,notijl' .I_'~cb "'0 "1!1 rllla2 -">iL Sln.tc!/ 7/21/97 ltt.ii'oc:l'Wl,. r.",.. DOXAlJ) x, E\"UltT. nt:'4 oIl'd.. Cou." . . ".. ~ " ' . ,.' , . ' :.'.:" :":..'>. :'.f::~:,." '": '::i.\i'::~:~~~:,~:,~:'\?d;:;d :R::;;;i;:r':<::':f.~', ,';",::::,\ ;,::': ':".:"'<"" - 71'7 - 5-.(,/- K'l/(p '. 1 . ) , . . - :'~'''','''''''''A'''';,_""",",'''''''~ .. '.'. ~ j/ DVSCP PAGE 02 ~ fl~~ :tt 3cJ .~~ ~.h .13,1~(?'7.... 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CJ.:r I c.:CD frY), It;Cf +; ['7i.).~~~~~~fs~~lU,? - . . - f'UlNtFtl'I b:HIIrT I I . \ . 1 91 ~ . ~i JULIE 1 ., ~ Plaintiff . . IN THE COURT OF COMMON PLEAS OF LYCOMING COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 9 0 2 127 PROTECTION FROM ABUS~ PENNAY, i ,I i RAYMOND V:~YD' :1 II 'I ii ,I . . : : : Defendant . . PROTECTION AGAINST ABUSE ORDER AND NOW, this II day of S?,I- and upon Plaintiff's showing , 1990, after :1 a hearing on the Complaint for Relief I : during the ex parte proceeding that there is cause to believe that ii ': there may be inunediate and present danger to the Plaintiff, it is '1 ~ hereby ORDERED and DIRECTED as follows: i! 1 1. The Defendant, Raymond Boyd, shall not initiate j contact with, harass, nor abuse the Plaintiff pending further Order 'j :1 i of Court. 2. ~laintiff, Julie pennay, is granted exclusive j possession of the residence at 815 West Fourth Street, i j Williamsport, Lycoming County, Pennsylvania, which means that the ~ ~ l Defendant may not go to, enter, or attempt to enter the home at I that address, this provision shall apply to all other addresses at ! I which the Plaintiff may reside. 3. Plaintiff shall be permitted to return to the residence ~ to obtain her personal clothing if accompanied by a police officer. 1 ~ 1 Such recovery of personal belongings shall be limited to twenty (20) i minutes to avoid confrontation of the parties, as well as to rele.se , ;; ; said law enforcement persons to their duties. Reasonable efforts ! shall be ..de by Plaintiff and the police e time convenient to Celendant. to arrante luch a return tt. ""t;" ... . ~ - - - '" .' " V \:tO~ - .., -. x .. jof I I '" ~ , i I ii of abuse ~ parties 4. This Temporary Order is entered to bring about a cessation until a hearing can be held on the Complaint with all the present. A hearing regarding this matter will be held on i 'I the Ii '! /9' day of Sepr , f , 1990, at / /0- L.M. i o'clock in Court Room No. H ~Williamsport, Pennsylvania. The Defendant is hereby advised of 'I his right to appear and be represented by counsel at the hearing. II , Lycoming county Court House, ~ II Lycoming County Sheriff or a competent adult. A true and correct copy ~Will be served upon the Williamsport Police Department which shall :j i have the authority to enforce this Order. 5. Service of the Complaint and order shall be made by the ;i :i 6. Defendant's violation of this order, including any ,I j attempt to enter Plaintiff's residence, upon information from the :: Plaintiff, may be regarded as the basis for a charge of indirect , criminal contempt of court. If convicted, Defendant may be sentenced ,1 I to pay a fine of not more than $1,000 or a prison term of not more l than six (6) months, or both. The court may also award any relief ! , authorized by the Act, including a direction to Defendant to pay reasonable fees to Plaintiff's attorney. I i i I I I BY TUE COURT. /r / ,e,# Ihnn; , J. I I j i ~ : JULIE PENNAY, Plaintiff IN THE COURT OF COMMON PLEAS OF LYCOMING COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 9 0 2 1 278 PROTECTION FROM ABUSE vs. RAYMOND BOYD, I Defendant COMPLAINT FOR PROTECTION FROM ABUSE 1. Plaintiff is an adult individual presently residing at 815 West Fourth Street, Williamsport, Lycoming County, Pennsylvania, , and ;1 the i " il 35 :1 brings this action on behalf of herself, Julie pennay, under Protection From Abuse Act, P.L. 1090, No. 218 of October 7, 1976, 5510181, !! seq., as amended (herein called "the 2. Defendant is an adult individual residing at :! 861 Park Avenue, Williamsport, Lycoming County, Pennsylvania. P.S. Act".)~,. e,;" :::l- 0:: ....' ~ => ~, (. ,. t- ,r ~t (~. ~ 3. The parties are family or household members within EH8 __ -. ~ . ,meaning of th~ Act, having resided together for nearly three years. 4. Defendant has committed acts of abuse as defined in the - . <-0 = Act against Plaintiff. Specific incidents which have occurred include, but are not limited to the following: (a) On September 1, 1990, Defendant punched Plaintiff in her face, pushed her onto the bed and choked her. Plaintiff retaliated by kicking Defendant in his ribs, slapping him and generally fighting back. The police were called. Cb) In April, 1990, Plaintiff walked into the bedroom and found a noose hanqioq from the ceiling with a teddy bear in the noose. Defendant told Plaintiff she would be next. -, Ic) In January, 1990, Defendant slapped Plaintiff in I :1 'I .1 her face. Id) plaintiff had a prior Protection Order against Defendant in June, 1988. :, :1 ii danger ,I Ii Order '; 5. plaintiff avers that there is immediate and present from Defendant to herself, and seeks a Temporary protection prior to full hearing. WHEREFORE, plaintiff respectfully prays for: !I 'I A. The immediate entry of a Temporary protection Order !J ~ granting the following relief: 11 'I (1) Directing the Defendant to refrain from initiating contact with, harassing or abusing the plaintiff: and (2) Granting Plaintiff exclusive possession of the premises a~ 315 West F~u=th Str~~~, Wiltismspo~t. Pennsylvania. B. After hearing, the entry of a continuing protection i Order I i l I! II) Granting any and all relief appropriate under the Act: (2) Directing that all costs of this proceeding be waived or taxed to Defendant: and (3) Directing Defendant to pay a reasonable re. to plaintiff's attorney. SUSQUEHANNA LEGAL SltRVICU 8Y'~~~~. Attorney 1.0. Mo. 57975 Attorney for Plaintiff I' . ! ., " :JULIE PENNAY, " IN THE COURT OF COMMON PLEAS OF : LYCOMING COUNTY, PENNSYLVANIA Plaintiff . . vs. : CIVIL ACTION - LAW NO. . . :RAYMOND BOYD, . . Defendant : PROTECTION FROM ABUSE ORDER AND NOW, this /0 day of September, 1990, the Court finds :Ithat the Plaintiff, Julie pennay, does not have funds available '1 'I . "to pay the court costs assoclated with the above-captioned action :!incIUding, without limitation, filing and service fees, and she is 'i 'i permi tted to proceed wi thout the prepayment of such costs. If BY THE COURT, .. 1>/ K-I ~ J. C; .... ,.. "'lII. ""t ::Ill- '<C '"' 0 -=0 ~, I:~ . '.:: ~ .. (": 'i . ,.. "". ~ # ::Ill- lit;:' . ~ \ \ , \ . '. r . . t . , . . , , , I , ! i'" , -. ~ JULIE PENNAY, : IN THE COURT OF COMMON PLEAS OF : LYCOMING COUNTY, PENNSYLVANIA Plaintiff vs. . . CIVIL ACTION - LAW NO. I RAYMOND BOYD, . . Defendant : PROTECTION FROM ABUSE , J I jassociated with the foregoing matter, including, without limitation, ~filing or service fees. 'I I do not have funds available to pay the court costs I verify that the above statement is true and correct. .1, I ,I understand that false statements herein are made ~ubject to the ,. penalties of il author! ties. 18 Pa. C.S. 54904 relating to unsworn falsification to , , ~ . r &u 7rt t. ,<Tlllle Pen nay ,j I . < I 1 j l j j , 1 ,- '" . I 7lo 9 ,,- G, () 3/ C,.;,:.I'- u.- 11 v. IN THE COURT OF COMMON PLEAS DAUPHIN COUNTY, PENNSYLVANIA NO. 4191~91r1 CML ACTION - LAW PROTECTION FROM ABUSE Julie Pennay, Petitioner Raymond Lewis Boyd, Respondent NOTICE TO DEFEND yOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must appear at the hearing scheduled herein. You are warned that if you fail to do so the case may proceed without you and an Order may be entered against you for the relief requested in the Petition. You may lose money or property or other rights important to you. If a copy of the TEMPORARY ORDER is attached, you must obey it until the hearing. If you do not obey it, the police can arrest you. YOU SHOULD TAKE TIllS PAPER TO YOUR LAWYER AT ONCE. yOU HAVE A RIGHT TO HAVE AN ATl'ORNEY REPRESENT YOU AT THE HEARING. 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 MAY GET LEGAL HELP. AVISO PARA DEFENSA USTED HA SIDO DEMANDADO ENLA CORTE. 5i usted quiere defenderse de Ins reclamaciones descritas in las paginas siguientes usted debe asistir a la vista que esta citada en esta. Usted esta seindo advertido de que si falls en asistir a In vista el caao procedera sin usted y una Orden puede ser expedida en contra SU)'Il para el remedio solicitado en la peticion. Usted puede perder dinero 0 propiedad u otros derechos importantes para usted. 5i In copia de una Orden Provisional esta acijunta usted debe obedecerla hasta que la ,ista se Ueve a cabo. 5i usted no In obedece In policia 10 puede arrestar. Uated debe Uevar este documento.au abopdo enseguida. Uated tiene derecho . tener un abopdo que 10 represente en 1a name ala siguiente olicina donde la infbrmann donde c:onseguir ayuda legal. Dauphin County LaWJW Referral Service 213 North Front Street Harrisburc. PA 17101 (717) 232-7536 ~.. fJHIIf c: "- ") l > f 1 h, 'tl v. IN THE COURT OF COMMON PLEAS DAUPmN COUNTY, PENNSYLVANIA NO. 1-/1 1 ~/r'l'f CMLACTION. LAW PROTECTION FROM ABUSE Julie Pennay. Petitioner Raymond Lewis Boyd, Respondent PETITION FOR PROTECTION FROM ABUSE TO THE HONORABLE MOTION JUDGE: The Petition of Julie Pennay, by her attorney, Latisha K. Frederick, pursuant to the Protection from Abuse Act, 23 Pa.C.S. ~6701, et sea.. as amended, respectfully represents as follows: 1. Petitioner is an adult individual presently residing at 404 Swatara St., Dauphin, PA 17018. 2. Respondent is an adult indi..idual residing at 404 Swatara St., Dauphin, P A 17018. 3. The relationship between Petitioner and Respondent is boyfriend and girlfriend. 4. Petitioner is not currently employed. 5. , Respondent is currently employed through JFC Temps. 6. Petitioner and Respondent have no minor cbildren together. 7. Respondent has engaged in abusive conduct toward Petitioner as such conduct is defined in the Protection From Abuse Ad. EKamplea of said conduct include, but are DOt limited to, the following: a. On October 9, 1994 Respondent aU~ Petitioner, kicbd her in the head auslnc a concussion, tried UI choke her, and il4,.ented her &om ...111"1 the pollce. . b. Respondent cames a razor in his wallet and threatens Petitioner with it, while referring to the murders of Nicole Brown Simpson and Ron Goldman. 8. Petitioner believes that she is in immediate and present danger of further abuse and harassment from Respondent, and that she is in need of, and entitled to, protection from such abuse. WHEREFORE, pursuant to the Protection From Abuse Act, Petitioner prays your Honorable Court to: I. Immediately enter a temporary order, pursuant to Section 5(b) of the Act, 23 Pa.C.S. ~6707 (B): A. Directing Respondent to refrain from approaching, abusing, harassing, or threatening Petitioner, either physically or verbally, wherever she may be; B. Prohibiting Respondent from having any contact with Petitioner, including by telephone or otherwise, except through her attorney; C. Directing Respondent to refrain from all harassing communication with Petitioner's relatives D. Directing Respondent to relinquiah immediately any firearms or weapons he may own, possess, or control, to the Dauphin County Sheriffupon being served herewith. n. After hearing to be held within ten days oft.he tiling hereof, and pursuant to Section 1 of the Act, 23 Pa.C.S.16708 enter a bat protection order continuing the relief act forth above, for a period of one year or until the Respondent appeals this honorable court'sonier, whkheveris earlier, and furtherrequiriDc that ReapJndent: A. Punuant to Section 5(d) ofUle Act. 23 Pa.c.s. ft,i07 <Dl. pay all taxable coats of this action. B. Pay attorneys fea in the 9~tof'$250.00. v. IN THE COURT OF COMMON PLEAS DAUPHIN COUN'IY, PENNSYLVANIA NO. CML ACTION - LAW PROTECTION FROM ABUSE Julie Pennay, Petitioner Raymond Lewis Boyd, Respondent TEMPORARYPROTEcnONORDER And now, this17th day of October, 1994, upon presentation and consideration of the within Petition, we order as follows: 1. Respondent is prohibited from approaching, abusing, threatening, or harassing Petitioner, either physically or veIbally, wherever she may be. 2. Respondent is prohibited from entering or attempting to enter Petitioner's current residence or any other residence Petitioner may choose to establish. 3. Respondent is directed tD refrain from all harassing communication with Petitioner's relatives. 4. Respondent is prohibited from contacting Petitioner in any manner, including by telephone orothenrise, except through her attorney, Latisha K. Frederick, 909 N. 2nd Street, Harrisburg, PA 17102, (717) 236-8241. 5. Respondent is directed tD relinquish immediately any firearms or weapons he may own, possess, or control, tD the Dauphin County SherifTupon being served herewith. 6. The Prothonotary, Sheriff, and local law enf'on:ement agencies, are directed tD accept, file and serve all copies of the Petition and Order without prepayment of costs. 7. A certified copy of the Order shall be served on the police department(s) in the jurisdiction where Petitioner resides. Punuant to Section 7(b) of the Act, a certified copy of this Order shall immediately be 61ed by the police department in the county registry of protection orden. Should the police come into contact with Respondent, and should Respondent allep that be has DOt been ~ ...d with this Order, the police officer shall immediately sernt the Order upon Respondenl 8. This Order shall be enforced hy a law enton:ement arency in any county where a violation O<<'W'S. & provided in Section 100c) of the Act, 'a)n arrestl'or violation of an order issued pursuant to this act may be without warrant upon probable C'llUH whether or not the violation is ftVII"'itted in the presence of the police JULIE MARIE PENNAY, Plaintiff . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PROTECTION FROM ABUSE : v. RAYMOND LEWIS BOYD, Defendant : : 97-3875 CIVIL TERM IN RE: PROTECTION ORDER ORDEROFCO~T AND NOW, this 24th day of July, 1997, upon consideration of the Plaintiff's Petition for Protection Order under the Protection from Abuse Act and following a hearing held on this date in which Plaintiff was represented by Joan Carey, Esquire, and the Defendant failed to appear for the proceeding, notwithstanding that he received notice of it, the Court finds that the Defendant has knowingly engaged in a course of conduct and repeatedly committed acts toward the Plaintiff under circumstances which have placed her in reasonable fear of bodily injury, and consequently it is ordered and directed as follows: 1. The Defendant, Raymond Lewis Boyd, is enjoined froa physically abusing the Plaintiff, Julie Marie Pennay, and from placing her in fear of abuse. 2. The Defendant is enjoined from havinq any direct or indirect contact with the Plaintiff, including but not li*ited to, telephone and written communications. 3. The Defendant is enjoined from harassing and/or stalking the ~laintiff and frea hara.sing and/or stalking any of her relatives. ~ 4. The Defendant is prohibited from entering the Plaintiff's place of employ~ent. 5. The Defendant is prohibited from removing, damaging, destroying or selling any property owned by the Plaintiff. 6. The Defendant is ordered to stay away from the Plaintiff's residence located at Apartment 1, Valley Ridge Apartments, 371 Claremont Drive, Carlisle, Cumberland County, Pennsylvania, and from any other residence the Plaintiff may in the future establish for herself. 7. The Defendant is ordered to pay $250.00 to CUmberland County, one of the funding sources of Legal Services, Inc., in lieu of attorneys' fees, as reimbursement for the costs of litigating this case, and any costs, including the $25.00 surcharge, provided for in the Protection from Abuse Act. 8. This order shall remain in effect for a period of one year or until further Order of Court. 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 a pattern and practice that indicates a risk of harm to the Plaintiff. 9. A violation of this order may subject the defendant to: (i) arrest under 23 Pa.c.S. Section 6113; (ii) a private criainal complaint under 23 Pa.C.S. SectIon 6113.1; CERT! Fl CATI ON OF PFA CONTEMPT Case Number q7- 387S ~l.J.. T.vt.4~ Name ~ <{~ ~r:L I). 3 J. J M Jtu.t.;t kk'Uf.. PA 1780/ , , Victim's Name: ~ JnMu.- f1~ Balance Due: S 3'f5: SO 170 State Surcharge ADD DELETE S 35".00 s s s s s S 10.00 S S 15.00 S 171 State Fine 260 Sheriff Cost ISl.50 + any addtl) 207 District Attorney 204 Court Costs IClerk of Court) 502 Restitution Name fMt1~A- &~ Address S 45, so $ City State Zip Name 1k.i~tf7\J~ Jil..wy Address ~ $ Jro.OO $ City Stolte lip Name "daress City St..te lip Prothonotary Office Penon Cer-tifYlnq Infol""'ttloll tJ.,Ak.(~(ll't.:"ilt~ oate $~Z JnL-".j-';~ THII>'- ;'1 E'I';'};',', ',' :;:",':;: .:, I" -,-: ',;" .- . - .' . ':'.' "I' ;'.......... ... ,.' .... . "" I.. I. _ -:. _. In The COlIl't of COnllllon Picas 01 l;UlI1lJCI'1:11lU t..ollllry, r'cnll~) 1"01 n 1<1 Julie Marie pennay f, I VS. Raymond Lewis l'oyd No. 97-3875 (;,i,vil Term .!~- Now, .July 18. 1997 19_,1 SHERlff OF' CUMBERLAND COUNTY,I'A do bereb~ depulitelhe Sberiffor llninn County 10 uec~te rhi. Writ,lhis deput.linn hein:: mad. 'llbe request.ad riskorlbe PI.inUrr, ~ ~ ~ . eo.'.! 1~e Sh.,irr orCumbe,bad Coual), P.. Affidavit or Service No.., July 21. 1997 ..1 10:25 o'clork A ~t.lCr..d'h. ,.ilhin Fn:etcltxn fum Ah.re. 1STtut'atY ~. ~. Ietit:im for Ptta:x:tim Q.ti!r. Imt:ru::tial to t1-e M..dsc: upoo RAYMOND I.RloIIS BOYD .1 his p~i~e of employment. RT 1) North. Lewisburg. Kelly Township'. Union County h~' h.ndin: 10 RAYMOND kEWlS BOYD . IfQund .ltemd rop~ orlb. original n't~rim fran Ah.re.Ul:(0l:llI}' ClJ:cEr. Nx:ja)~t:im a'd Irsou:tjQifnl3d. known 10 _.._ him Ih. <"nluts Iher...r. So IIlS\~f". .... . "...... ....... - ~ ...... '...- ..... ,00 ~ .".. ,,"- *... !'.... ..~ ~ . . .....,.,".. .. ", "... :.-~ ,,,," ..,....oto \ .... .~ . ...... .... ". 5 r'" .~~,. .. /4..~1#d:: '; ',~ ~"!L1 l-~7fllL E. JAIl\:. '.:.t .:@.b - ._.~. -- -.--.. ,,(\.... ~~~..:.~~.~.,l!! (L.A4 .1 J:..':lt ~n C".l>,l'~. By a.1 - e. rdd1Ar.,J,,\ J~. Sc f3wder. Chl~f COSTS Deputy Sf.R\'tcr !. 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