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VICTORIA E. BARNES, I IN THE COURT OF COMMON PLEAS OF
Plaintitt I CUMBERLAND COUNTY, PENNSYLVANIA
I
V. .
.
.
.
REGINALD O. OBERTON, . PROTECTION FROM ABUSE
.
Defendant NO. 97-6067 CIVIL TERM
IN RE: CONTEMPT
ORDER OF COURT
AND NOW, this 29th day of April, 1998, upon the
request of the District Attorney, disposition on the petition
for indirect criminal contempt is deferred pending the rehearing
to be scheduled at the call of the District Attorney. Pending
said rehearing, Defendant is released on ROR bail on the express
condition that he comply with this Court's order of November 7,
1997.
By the Court,
J.
John A. Abom, Esquirft
Assistant Diatrict Attorney
For the Plaintiff
c~ I"'-~ lilll?.!,
..,J. 'P.
Ellen K. Barry, Esquire
Assistant Public Oefender
For the Oefendant
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Victoria E. Barnes.
Plaintiff
IN TilE COURT OF COMMON PLEAS OF
v.
CUMBERLAND COUNTY. PENNSYLVANIA
NO. 97-/"01,,7 CIVIL TERM
PROTECTION FROM ABUSE
~eginald O. Oberton.
Defendant
TEMPORARY PROTECTION ORDER
AND NOW. this 31g- dny of t>t'~
. 1997,
upon presentation and consideration of the within Petition. and
upon finding that the plaintiff. Victoria E. Barnes, now residing
at 424 ~orth West Street. Carlisle, Cumberland County.
Pennsylvania. is in immediate nnd present danger of abuse from
the defendant. Reginald O. Oberton. the following Temporary Order
is entered.
The defendant, Reginald O. Oberton. (SSN: unknown and date
of birth: unknown) now residing at 146 West Penn Street.
Carlisle, Cumberland County. Pennsylvania. is hereby enjoined
from physically abusing the plaintiff. Victoria E. Barnes. or
from placing her In fear of abuse.
The defendant Is ordered to stay away from the plaintiff's
residence located at 424 North West Street, Carlisle, Cumberland
County. Pennsylvania. a residence which is not owned or leased by
the defendant. nnd nny other residence the plaintiff may
establ ish.
The defendant is ordered to refrnln from having any direct
or indirect contnct wi th the plnint iff including. but not limited
to, telephone and written communications.
The defendnnt is enjoined from harassing and stnlking the
.
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plaintiff and from harassing the plaintiff's relatives.
The defendant is enjoined from entering the plaintiff's
place of employm~nt or the school of her minor child.
The defendant is enjoined from removing, damaging,
destroying or selling any property owned solely by the plaintiff.
A violat ion of 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. !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. 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 remllln in effect unt I I modi fied 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.
A hearing shall be held on this matter on the ~~ day of
~A!~~' , 1997, at -?:~ JD.m., in Courtroom No.~
, Cumberland 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 request and without pre-payment
of fees, but service mllY be accomplished under any applicable
rule of Civil Procedure.
This Ord~r shall be docketed in the office of the
Prothonotary and forwarded to the Sheriff for service. The
Prothonotary shall not send a copy of this Order to the defendant
by mai I.
The Mechanicsburg and Carlisle Police Departments wi II be
provided with certified copies of this Order by the plalntlff'~
attorney. This Order shall be enforced by any law enf~rcement
agency where a violation occurs by arrest for Indirect criminal
contempt without warrant upon probable cause that this Order has
been violated, whether or not the violation Is committed In the
presence of the police officer. In the event that an arrest Is
made under this section, the defendant shall be taken without
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. g 61 t:l).
By the Court,
A/~. d4
,. Judge
TRUE COpy FROM RECORD
In TestImony Whereot, I here unto Mt my hind
and ttg ~ ot said at Carll. PI
day . ot ui .
Pr011l0notlry
Victor ill E. Barn"s.
Plaint i ff
IN TIfE COURT Of COMMON PLEAS OF
CUMRERLAND COUNTY. PENNSYLVANIA
v.
NO. 97-
CIVIL TERM
Reginald O. Oberton.
Defendant
PROTECTION FROM ABUSE
NOTICE
You have been sued in court. If you wish to defend against the
claims 5et forth 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 Court and
presenting to the Court your defenses or objections to the claims set
forth against you. You are warned that If you fall to do so the Court
may proceed without you, and a judgment may be entered against you by
the Court without further 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 up to $250.00 to reimburse one of Legal
Services. Inc. 's funding sources for Legal Services Inc. 's
representation of the plaintiff.
You should take this paper to your lawyer at once.
have a lawyer or cannot afford one, go to or telephone
forth below to find out where you can get legal help.
If you do not
the office set
COURT ADMINISTRATOR. 4th FLOOR
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PENNSYLVANIA 17013
TELEPHONE NUMBER: (~1 ~) 240-6200
AMERICANS WITH DISABILITIES ACT OF 1990
The Court of Common 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 court,
please contact our office. All arrangements must be made at least 72
hours prior to any hearing or business before the court. You must
attend the scheduled conference or hearing.
PETI'rION FOR PROTP.CTlIDlJllIDRB
RELIEF UNDER TilE PROTECTION FROM ABUSE
ACT, 23 Pa.C.S. B 6101 et seq.
A. ABUSI~
I. The plaintiff, Victoria E. Aarou~, Is an adult
individual residing at 424 North Wu~t Street, Carlisle,
Cumberland County, Pennsylvania 17013.
2. The defendant, Reginald O. Oherton, (SBN: unknown)(Date
of Birth: unknown), is an adult InclivldulIl residing at 146 West
Penn Street, Carlisle, Cumberland County, Pennsylvania 17013.
3. The defendant has had an Intimate relationship with the
plaintiff.
4. Since approximately the winter of 1997, the defendant
has attempted to cause and has Intentionally, knowingly, or
recklessly caused bodily Injury to the plllintlff, has placed the
plaintiff in reasonable fear of Imminent serious bodily Injury,
and has knowingly engAged in a course of conduct or repeatedly
committed actll toward the plaintiff Including following the
plaintiff, without proper authorization, under circumstances
which have placed the plaintiff In reasonable fear of bodily
injury. This hilS Included, but is not limited to, the following
specific Instances of abuse:
a. On or about October 14, 1997. the defendant waited
for the plaintiff in the parking lot of her employer
causing her to fear for her safety.
b. In or about August 1997. the defendant hit the
plaintiff. grabbed her, and shoved her up against the
car. The defendant choked the plaintiff until she
almost passed out, hit her body and head with the cast
on his arm causing pain. bruises. and a difficulty in
swallowing.
c. In or about July 1997, the defendant grabbed the
plaintiff, pushed her onto the bed. and hit her several
times on the legs causing swelling and bruising. The
defendant continued to push the plaintiff onto the bed.
slap her, and pull her hair causing bruises.
d. On several occasions since the winter of 1997, the
defendant has shoved. restrained, choked, punched.
kicked, and slapped the plaintiff causing bruises and
scars. The defendant has thrown objects at the
plaintiff. punched walls. and cut the plaintiff's
clothing. On several occasions, the defendant has
attempted to burn her with cigarettes and has
threatened to kill her causing her to fear for her
life.
5. The plaintiff believes and therefore avers that she is
in immediate and present danger of abuse from the defendant and
2
that sh~ is in need of protection from such abuse.
6. Th~ plaintiff desires that the defendant be prohibited
from having any direct or indirect contact with the plaintiff
including, but not limited to, telephone and written
communications.
7. The plaintiff desir~s that the defendant be enjoined
from harassing and stalking the plaintiff, and from harassing the
plaintiff's relatives.
8. The plaintiff desires that the defendant be restrained
from entering her place of employment or the school of her minor
child.
9. The plaintiff desires that the defendant be enjoined
from removing, damaging, destroying or selling any property owned
solely by the plaintiff.
B. EXCLUSIVE POSSESSION
10. The home which the plaintiff is asking the Court to
order the defendant to stay away from is not owned or rented in
the defendant's name.
11. The defendant has his own residence located at 146 West
Penn Street, Carlisle, Pennsylvania.
C. REIMBURSEMENT FOR COST OF CASE
12. The plaintiff asks that the defendant be ordered to pay
$250.00 to reimburse one of Legal Services. Inc. 's funding
sources for the cost of litigating this case.
3
WHEREFORE, pursuant to the provisions of the "Protection
from Abuse Act" of October 7, 1976, 23 Pn.C.S. g 6101 tl J!.!UI.., as
amended, the plaintiff prays this Honorable Court to grant the
following relief:
A. Grant n Tempornry Order pursuant to the
"Protection from Abuse Act:"
1. 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 plnintiff and from
harassing the plaintiff's relatives.
4. Prohibiting the defendant from entering the
plaintiff's plnce of employment or school of her
minor child.
S. Prohibiting the defendant from removing,
damaging, destroying or selling property owned
solely by the plaintiff.
6. Ordering the defendant to stay away from the
plaintiff's residence located at 424 North West
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Street, Carlisle, Cumberland County, Pennsylvania,
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and any other residence the plaintiff may
establish.
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. Ordering the defendant to refrain from
abusing the rlaintiff 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 the plaintiff's relatives.
4. Prohibiting the defendant from entering the
plaintiff's place of employment or the school of
her minor child.
S. Prohibiting the defendant from removing,
damaging, destroying or selling property owned
solely by the plaintiff.
6. Ordering the defendant to stay away from the
plaintiff's residence located at 424 North West
Street, Carlisle, Cumberland County, Pennsylvania.
and any other residence the plaintiff may
5
establish.
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 hearing, and that certified copies
of this petition and Order be delivered to the Mechanicsburg and
Carlisl~ Police Departments which have jurisdiction to enforce
this Order.
The plaintiff prays for such other relief as may be just and
proper.
RespectfullY submitted,
~~~~'
Jo' Carey, Att~ne~f~laintiff
LEGAL SERVICES, INC.
8 Irvine Row
Carlisle, PA 17013
(717) 243-9400
6
The above-named plaintiff, Victoria E. Barnes, verifies that
the statements made in the above Petition are true and correct.
The plaintiff understands that false statements herein are made
subject to the penalties of 18 Pa.C.S. g 4904 relating to unsworn
Date:
{Oko!47
, I
falsification to authorities.
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Victor ill E. Bllrnl'S,
Plaint i ff
IN Tm; COURT or COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 'l7-(,0c:''F1VIL TERM
Regi~ald O. Oberton,
Defendllnt
PROTECTION FROM ABUSE
AND NOW, t his
ITMPORARY PRon;r.-r:.liltLQRI!f.R
.J1_~'! dllY of_Qd4!J_~__,
1997,
upon presentntion IInd consideration of the within Petition, and
upon finding thllt the plllintiff, Victoria E. Anrnes, now residing
at 424 North West Street, Carl isle, cumherlllnd County,
Pennsylvllnia, is in immediate and present danger of abuse from
the defendant, Reginald O. Oberton, the following Temporary Order
is entered.
The defendant, Reginald O. Oherton, (SSN: unknown and date
of birth: unknown) now residing nt 146 West Penn Street,
Carlisle, Cumberland County, Pennsylvania, is hereby enjoined
from physically abusing the plaintiff, Victoria E. Barnes, or
from placing her in fenr of abuse.
The defendant is ordered to stay away from the plaintiff's
residence located at 424 North West Street, Carlisle, Cumberland
County, Pennsylvania, a residence which is not owned or leased by
the defendant, nnd any other residence the plaintiff may
establ ish.
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 und from harassing the plaintiff's relatives.
The defendant Is enjoined from entering the plaintiff's
place of employment or the school of her minor child.
The defendant is enjoined from removing, damaging,
destroying or sel ling any property owned solely by the plaintiff.
A violat ion of this Order may subject the defendant to: i)
arrest under 23 Pa.C.S. g6113; i i) a private criminal complaint
under 23 Pa.C.S. g6113.lj iii) a 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 null ify 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.
A hearing shall be held on this matter on the ~_ day of
/IOvLrnJfI(.. ,1997, at .1i..OtJ/!.m., in Courtroom NO.~
, Cumberland County Courthouse, Carlisle, Pennsylvania.
The plaintiff may proceed without pre-payment of fees
pending a further order after the heuring.
The Cumberland County Sheriff's Department shali attempt to
muke service at the plaintiff's request and without pre-payment
of fees, but service may be accomplished under any applicable
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Victoria E, BarnCK.
Pia i nl iff
I N TilE COURT OF COMMON PI.E,\S OF
CUMRERI.AND COUNTY, PENNSYLVANIA
v .
NO. 97-
CIVIL TERM
Reginald O. oberlon,
Defendunt
PROTECTION FROM ARUSE
NOTICli
You have been sued in court. If you wish to defend against the
cluims set forth in the following pages, you must take action promptly
after this Petition, Order and Notice arc seeved, by appearing
personally or by attorney at the hearing scheduled hy the Court and
presenting to the Court your defenses or objections to the claims set
forth IIgainst you. You are warned Ihllt if you fai I to do so the Court
mllY proceed without you, and a judgment may be entered against you hy
Ihe Court without further notice for any owney claimed in the Petition
or for any other claim or rei ief requested hy the plaint iff. You may
lose money or property or other rights important to you.
fEE.lLAN1LmSTS
If the case goes to hearing and the judge grants a Protection
Order, a surcharge of $15.00 will he assessed against you. You may
also be required to pay up to $J50.00 to reimburse one of Legal
Services, Inc.'s funding sources for Legal Services Inc,'s
representation of the plnint iff.
You should take this paper to your lawyer at once. It you do not
have a lawyer or cannot afford one, go to or telephone the offic~ set
forth below to find out where you can get legal help.
COURT ADMINISTRATOR, 4th FLOOR
CUMRERLAND COUNTY COURTHOUSE
CARLlSI.E, PENNSYLVANIA POIJ
TELEPHONE NUMBER: (71") J40-6200
AMERICAN./LWIJH f)ISAnlLlTIES ACT OF 1990
The Court of Common Pleas of cumherlnnd County is required by
to comply with the Americans with Disabil ities ,\ct of 1990. For
information ubout "ccessible facilities and rcusnnable accommodat
available to disabled individunls having husiness before the cour
please conlnet our nffice. All nrrnngements must he made at 1
hours prior to "ny hearing or husiness before the court. You
nttend the scheduled conference or hearing.
II. On or llbout October H, If)f)7, the defendant waited
for the plllintirf in the pnrking lot of her employer
cnusing her to fear for her Rafety.
b. In or about August IfJQ7, the defendllnt hit the
plaintiff, grabbed her, and shoved her up against the
car. The defendant choked the pllllntiff until she
almost passed out, hit her body and head with the cast
on his arm causing pain, bruises, and a difficulty in
swallowing.
c. In or ahout July 1997, the defendant grabbed the
plaintiff, pushed her onto the bcd, and hit her several
times on the legs cnusing swelling and bruising. The
defendant continued to push the plaintiff onto the bed,
slap her, and pull her hair causing hruises.
d. On several occasions since the winter of 1997, the
defendant has shoved, restrained, choked, punched,
kicked, and slupped the plnintiff causing bruises and
scars. The defendant has thrown objects at the
plaintiff, punched walls, and cut the plaintiff's
clothing. On several occasions, the defendant has
attempted to hurn her with clgnrettes and has
threatened to kill her causing her to fear for her
life.
S. The plnintlff believes and therefore avers that she is
in immediate and present danger of abuse from the defendant and
2
that she is in need of protect ion from such ahuse.
Ii. The plaintiff desires that the defendant he prohihited
from having any direct or indirect contact with the plaintiff
including, but not limited to, telephone and written
communications.
7. The plaintiff desires that the defendant b~ enjoined
from harassing and stalking the plaintiff, and from harassing the
plaintiff's r~latives.
S. The plaintiff desires that the defendant be restrained
from entering her place of employment or the school of her minor
ch i Id.
9. The plaintiff desires that the defendant be enjoined
from removing, damaging, destroying or selling any property owned
solely by the plaintiff.
B. EXCLusrVE POSSESSrON
10. The home which the plaintiff is asking the Court to
order the defendant to stay away from is not owned or rented in
the defendant's name.
11. The defendant has his own residence located at 146 West
Penn Street, Carlisle, Pennsylvania.
C. RErMBURSEMENT FOR COST OF CASE
12. The plaintiff asks that the defendant be oedered to pay
$250.00 to reimburse one of Legal Services, rnc. 's funding
sources for the cost of litigating this case.
J
WHEREFORE, pursuant to the provisions of the "Protection
from Abuse Act" of October 7, 1976, 23 P/I.r..S. g 6101 tl ~., as
amended, the plainti ff prays this llonorable r.ourt to grant the
following relief:
A. Gr/lnt a Temporary Order pursuant to the
"Protection from Abuse Act:"
I. Order ing 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 I imi ted to, telephone and
written communications.
3. Ordering the defendant to refrain from
harassing and stalking the plaintiff and from
harassing the plaintiff's relatives.
4. Prohibiting the defendant from entering the
plaintiff's place of employment or school of her
minor chi ld.
S. Prohibiting the defendant from removing,
damaging, destroying or selling property owned
solely by the plaintiff.
6. Ordering the defendant to stay away from the
plaintiff's residence located at 424 North West
Street, Carlisle, Cumberland County, Pennsylvania,
4
and any other residence the plaintiff may
establ ish.
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 II period of one yellr:
I. Ordering the defendllnt to refrain from
abusing the plaintiff or from pla~ing her in fear
of abuse.
2. Ordering the defendant to refrain from having
any direct or indirect contact with the plaintiff
ineluding, but not limited to, telephone and
written communications.
J. Ordering the defendant to refrain from
hllrasslng and stalking the plaintiff and from
harassing the plaintiff's relatives.
4. Prohibiting the defendant from entering the
plaintiff's place of employment or the school of
her minor child.
5. Prohibiting the defendant from removing,
damaging, destroying or selling property owned
solely by the plaintiff.
6. Ordering the defendant to stllY away from the
plaintiff's residence locllted lit 424 North West
Street, Cllrlisle. Cumberlllnd County, PennsylvanIa,
and any other residence the plaintiff may
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~ Thc court costs IInd fccs art' wllivl.d.
8. This ordcr shllll rcmain in cffcct for u period of one
ycar or unti I modified or terminated hy thc rourt. The Order clln
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 pract ice thut indicates cont inued
risk of harm to the plaintiff.
9. ^ violation of this Order mllY subject the defendant to:
i) arrest under 2] Pa.C.S. 9611]; il) a private criminal
complaint under 23 Pa.C.S. 9611].1; iii) a charge of indircct
criminal contempt under 23 Pa.C.S. 96114, punishahle by
imprisonmcnt up to six months IInd a fine of $100.00-$1,000.00;
and iv) civil contempt under 23 Pa.C.S. 96114.1. Resumption of
co-residence on thc part of the plaintiff and defendant shall not
nullify the provisions of the court order.
10. The Carlisle and Silver Spring Township Policc
Departments shal I be provided with certified copies of this Order
by the plaintiff's attorney IInd moy enforce this Order by arrest
for Indirect criminal contcmpt without warrant upon probable
cause that this Order has heen violated, whether or not the
violation is committed in the presence of a police officer. In
the event that an arrcst is m"de undcr this sect ion, the
defend"nt shllll hc taken without unncccssllry delay before the
court that issucd the order. When Lhat court Is unavai lable, the
defendunt shull be taken before the appropriate district justice.
(23 PU.C.S. S 6113).
Ily the Court.
't.k
Joan Carey - ~~ /I'7.~)
Attorney for Plhintlff
Reginald O. Oberton.~ /I4.A'.ibt /1/7/'17
Pro Se
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r~,'j""J' '"'';';A'''
... I, 14,'"1\.
il'7.c;,? &c/.d9/t1 ~ ~ ~S.
'.
Victoria E. narnes.
Plaintiff
IN THE COURT Of COMMON PLEAS OF
v.
CUMnERLAND COUNTY, PENNSYLVANIA
NO. 97-6067 CIVIL TERM
Reginald O. Oberton,
Defendant
PROT~CTION FROM AnUSE
CONSENT AGREEMENT
This Agreement is entered on this 3fn day of November.
1997, by the plaintiff, Victoria E. narnes, and the defendant,
Reginald O. Oberton. The plaintiff Is represented by Joan Carey
of LEGAL SERVICES, INC.; t he defendant is unrepresented hut is
aware of his right to have an attorney. The parties agree that
the following may he entered as an Order of Court.
I. The defendant, Reginald O. Oberton, agrees to refrain
from abusing the plaintiff, Victoria E. Darnes, or from placing
her in fear of ahuse.
2. The defendant agrees not to have nny direct or indirect
contact with the plaintiff including, hut not limited to,
telephone and written communications.
3. The defendant agrees not to harass and stalk the
plaintiff and not to harass the plaintiff's relatives.
4. The defendant agrees not to enter the plaintiff's place
of employment or the school of her minor child.
5. The defendant ngrees not to remove, dnmage, destroy, or
seli any property owned hy the plnintiff.
6. The defendant agrees to stny away from the plaintiff's
residence locnted nt 424 West North Street, Cnrlisle, Cumberland
County, Pennsylvanin, and nny other residence the plnint!ff may
esta!>1 ish.
7. The defendant, although entering into this Agreement,
does not admit the 81 legations made in the Petition.
R. The defendant understands that the Protection Order
entered in this matter wi II be in effect for II period of one year
and can be extended beyond it originlll expiration date if the
Court finds that the defendant has committed another act of abuse
or hilS engaged in a pattern or practice thllt 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 case.
9. Violation of the Protection Order may subject the
defendllnt to: i) arrest under 23 Pa.C.S. g611J; i i) a private
criminal complaint under 23 Pa.C.S. g6113.1; iii) a charge of
indirect criminal contempt under 23 Pn.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.
WHEREFORE, the parties request that a Protection Order be
rertect the above terms.
/~~ A~
~"o. Oberton,
->
Defendant
Plllintiff
oan Carey
Attorney for PI
LEGAL SERVICES,
8 Irvine Row
Carlisle, PA 17013
(717) 243-9400
..
FllfD-Crl'HCE
CO T' ," 1'1' "\" rr'o...,ny
r 11.,'" t.. ,: ',il\. ,,"i'
C;1 'le" - S ~;~ 10: I. 3
C'" ," --, ..." ',' J' 'IY
V.\'.l""J'..r,.: .1.1 '.,It.lll'j.
PE.~i';S' L\/\t"~},
'G1
BAIL BOND
OTN OJ No:
CC No: DJ Docket No:
Commonwealth vs. (Defendant Name and Address)
Reginald Lawn Oberton
146 W. Penn St.
Carlisle, PA 17013
"'I . I.{' l,'/ (' ". Dale of Charge(s):
4/17/98
NEXT COURT ACTION Oalel Timel Location
Court of Common Pleas
CHARGE(S): Indirect Criminal Contempt
ADDITIONAL CHARGES MAY EXIST. PLEASE SEE ADDITIONAL CHARGES PAGE.
TYPE(S) OF RELEASE:
iik ROR
o Nominal Bail
o Unsecured Bail 0 Nonmonetary Condition(s) (see additional pagels))
o Monetary Condition(s) in the amount of $
-,
THE CONDITIC>>lS OF THIS BA BOND ARE AS FOLLOWS,
1. The defenda,;t must appear at all times required until full and final disposition oltha case.
2. The defendant must obey all further orders oltha ball authority.
3. The defendant must give written notice 10 the bail authority, the clerk of courts, the district a1l0rnay, and the court bail agency or other desIgnated court bail
officer, 01 any change 01 address within 48 hours of lhe dale of the change.
4. The defendant must neilher do. nor cause 10 be done, nor permit to bi done on hiSiher behalf, any act as proscribed by Section 4952 of Ihe Crimes Code
(relating to intimidation 01 witnesses or victims) or by Section 4953 (relaling 10 retaliation againsl witnesses or viclims), 18 Pa.C.S.~! 4952,4953.
5. The defendant must refrain Irom criminal activity.
~~
F SECURITY:
o Cash/Equivalent 0 Gov't Bearer Bonds
o _0/0 Cash 0 Surety Bond
TOTAL AMOUNT BAIL SET (IF ANY): $
o Realty wlin Commonwealth
o Realty outside Commonwealth
(~ee sureties page)
This bond is valid for the entire proceedings and until full and final disposition of
the case including all avenues of direct appeal to the Supreme Court of Pennsylvania,
I AGREE THAT I WILL APPEAR AT ALL SUBSEQUENT PROCEEDINGS AS REQUIRED AND COMPLY WITH ALL THE CONDITIONS OF THE BAIL BOND.
THJ5BONOSlGNEOON ~~ 20
r J\AlIslD
,,~
.
. PENNS'f1.VAN1A
~~
~
(S,~naIUl.ol o.r."""nlJ
daYOf~.19~
,SEAL)
JUDGE OR ISSUING AUTHORITY
DATE
My commission expires first Monday of January,
PLEASE SEE AffA':HEO "AGES feA ADOlTiONAlINFOAMA!:CN
AOPC 414Al.97
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF: CUMBERLAND
IN FORMA PAUPERIS
AFFIDAVIT/PETITION
~~ Oltl No
09-2-01
W N_ 101
PAULA P. CORREAL
....... EAST WING - COURTHOUSE
1 COURTHOUSE SQUARE
CARLISLE, PA
r,~__ 17171240-6564 17013-0000
DEFENDANT:
r
1~~C;ltJtlI-D
L
Docket No,: ~.jJ. -I Lj3- C,
Date Flied:
vs.
NAME Ind ADORUe
.,
lawj.) O\>(,,,totJ
STATEMENT OF THE PETITIONER
I hereby requesl Ihat this Court permll me 10 proceed in forma pauperis (wlthoul payment of the filing lee). In
support of Ihlsl slate Ihe following: .
~. I am the planlllf In the above malter and because of my IInancial condlllon am unable 10 pay Iha fee for
IIlIng Ihls acllon.
02. I am unable 10 obtain funds from anyone, Including my family and associales, 10 pay Ihe cosls 01 IIl1gallon.
03. I represent Ihallhe informallon below relating 10 my abllily 10 pay the fees and costs Is Irue amI correct:
NAME AND ADDRESS PRESENT EMPLOYER'S NAME AND ADDRESS
p'..";,,tllAw~, ()/,.."JIY'l Vdhff. 1//(g ~/ut, !- 'j"f"('.
/76 VoI,2v>", ,J. 01 " e.,i&;... S/
1"c.'?!/~ (0, pIJ I 7v/.3 (;r1/I~ ..j)Jj /7/)/ J
TELEPHONE' (), 7 ).:;0( ,? ?;,11 i
IOClAlSECUf'NNUUBER :;)/1" r;1{. ]J.-.l4 8AlAAV OR WAOE8 PEn MQNTH
",,,,,,,,WOOl< 'ihj,.I.!J.,:-. INCOME FOR TilE PAST 12 MONTIIS (CIIECK ONE)
AM PRESENTLY UNEMPLO ED 1. LESS TIIAN $20,000
''''''''''OF WVlA9TEWPlOYW'NIWAS &- LESS TIIAN $15.000
_OOWAO'.".")'"'' 3. LESS THAN $10,000
"'''OF WOOl< 4. LESS TIlAN $5,000
OTHER INCOME RECEIVED WITHIN THE PAST TWELVE MONTHS: I F NONE. PLEASE STATE "NONE"
BUSlNEBB OR PROFESSION ,1\.1 oAJt:. INTEREST
OOCIAl SECUATY BENEFITS $
WQflKMAN 5 'XlJ.IIPENSATlQN $
DMDf.N09
SUPPORT P....yJ,lENTS S
De r mon t h OlSABlUTY PAYMENTS S
per month PUBlICASSI9TANCE- S
D8r month "
OU1ER 8ElF-E~PlOyt.lENT
PfNSIQN AlolO ANNUllUE9
Der month
Der month
UNEt"WlOVl"ttN' CQt,IPENSATK)H AND SUPPlEMENTAl BENEFITS
OHiER
*IF SUP?ORT PAYMENTS ARE NOT CURRENT
CHECK HERE_
AOPC 822,\,92
PAOE 1 OF2
.
II Cue Name:
Dockel Number:
1\
I'T,r.i\!lf~ CIIECK ONE:
SIngle Separated Widowed
OTHER CONTRIBUTIONS TO ~IOUSEHOLD SUPPORT:Harr led IJlvorced QC...,
jWlF~lItlU8OANOI "VWE Y'-''J '(V'L 0 MY ('MfElltfUSBANOlI8 EMPlOYED
BPOUSE lJ EMPlOYER
SALAltvonWAQUPln J,lONTH
TYPE OF ~
COHTABUTION8 FFVM CllllonEN
COHTABunOHEI FROM PARENTS
OTHER CQtfTAOUflON8
PROPERTY OWNED IF NONE, PLEASE STA'!E "NONE"
CAStt- AJUAJi CHECklNOACCOUHT
SAVINGS ACCOUNT C(RTII'ICAIE90F OEP06IT'
REAl E8TAfE (tNClUOlNO ~tOMEI
MOTOR VftOClE UAJC.E
yEAJl
coo.
AMOUNT OWED I
STOCKS BONOO
OTHER
DEBTS AND OBLIGATIONS IF NONE, PLEASE
STATE "NONE"
REN' ':;00-
MORTGAGE
LOANS' / fq~' ~~
CIIILD SUPPORT: 3,;J.)~ ,IJ~
PERSONS DEPENDENT UPON ME FOR SUPPORT
o ftNIfElttfUSOANQ NAME
8- CHl.DREN. IF ANY
......A~,M~ \" ,~~
OTHER
NAME
~,~jJ /.. (XJ. Jd'
All, L..
All.
s-
......
AGE:
......,
o OHlER PEfI8ON9 . NAME
AGE:
.....,
All'
RELA TlONSHlP
NAME nELAT1ON5InP
~ndersland that I have a continuing obligation to Inform the Court of Improvement In my financial circum.
~ _ stances which would permit me to pay the costs Incurred herein.
~. I verily thatlhe statements made In this pelnlon are true and correct. I understand that false statements
herein are made subjeet to penanles of 18 Pa. C.S. See, 4904. relating to unSWQrn falsification to authorttles.
Datil: y.-:;?p /9' Slcnature of the Petitioner: . /~ /7 /-
?~ ~ /
l(- ;) rr 11(
Dale
. Dlstrlct Justice
My commission expires IIrst Monday 01 January, 2000
SEAL
AOPC 6228,93
PAGE 2 OF 2
,COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
CRIMINAL COMPLAINT AND
PROBABLE CAUSE AFFIDAVIT
....""'...
09201
OJ~. Han
COMMONWEALTH OF
PENNSYL V ANJA
VS.
--
PAULA P CORREAL
1 COURTHOUSE SQ
CARLISLE PA 17013
717 240 6565
NAME and ADORE S9
DEFENDANT:
,-
AKA:
REGINALD LAWN OBERTON
146 W PENN STREET
CARLISLE PA 17013 0000 00
REGINALD OBERTON
Oocl<et No.:
Dale Flied:
OTN:
*'
Ae9Mrlllon ~
Mnlolll $~ NumbIf
OlNNl.lll'lbtt
$lDN~bet
ComplU'llNl,Il\'\beI
I
UCR Numbtt
~642
54 7234
Complef\l Nl.Itnbtt, It 0CI'ItI' PlIlcpam.
IncidenINInl!>>f
19980400769 CAR
R.5.A.:
BM 27
D.O.B.: 01 07 1971
5.5.#: 211
ORI NO.: PA0210200
District Attorney's Office _ Approved -Disapproved because:
(The Dl.l11cl Anomev mev require !halthe complalnl, a"e.1 warrenl affldavll, or bolh be approved bv the allomav 10' Ihe Commonwaalth prior to filing.
Pa.R.C"P. 107.) When tha affianlla nole poIlca officer as dafined In Rula 51(C) and tha offan.a(.) charged Include(.) e mlademeano, 0' lalony which
doeI not Involva a clear and pra.anl danger 10 any person or Ihe community, the complalnlahall be .ubmllled 10 the allomev 10' Ihe Commonwealth. who
ahellapprove or dlaepprove wlthoul unreasonable delav). ~ A.4 ,f) C\.
(IUfAOar.1 lS~ IT
I, ,.............., PO THOMAS L DAY BADGE 25
of CARLISLE PD
rBslding at 53 WEST SOUTH ST CARLISLE PA 17013
do hereby stats: (check appropriale area)
1. -!. I accuse the above named defendant, who lives at the address set forth above or,
- I accuse an individual whose name Is unknown to me but who Is described as
- I accuss the defendant whoss name and popular designation or nlcknams Is unknown to me and whom I
have thsrefore deslgnatsd as John Doe
with y~l;1tif~~~Ifve8U'1'SE2mmonwealth of Pennsylvanls at: CARL,~:'..._
In (COlJnty) CUMBERLAND on or about 04 17 1998 2353 HRS
TO 04 17 1998 2200 HRS
Participants were: (II there we'e particlpenls place their names here, repealing name 01 above dalendanl)
2. The acts committed by the accused were: ," ,',
(Set lorth a .ummary 01 the laclS sufflclenllO advl.e Ihe delendanl ollha nalure 01 the offenae charged. Neither the evld<<lCe nor...... -
allegedlv v!oleled need be ciled, no, ahall a cllallon 01 Ihe slalule allegedlv vlolaled, bV ilaell, be aufflclent. In a aUl'MlAl'f CllH. Ullarlh. "
cilllion ollhe .peclfic aectlon and .ub..ecllon 01 the .Ialule or ordinance allegedly vlolaled),
.. INDIRECT CRIMINAL CONTEMPT - CSA1990 CTS 1
THE ACTOR DID VIOLATE THE PROTECTION FROM ABUSE ORDER
NUMBER 97-6067
THE ORDER WAS SIGNED BY THE HONORABLE HAROLD E. SHEELY
THE ORDER WAS DATED NOVEMBER 7, 1997
Copy: DISlnct JLlshce
Oel(l(lljanl
Relum 01 ServICe
Police
. Page 2
-
CRIMINAL COMPLAINT AND
PROBABLE CAUSE AFFIDAVIT
Delendant Name:REOINALD LAWN OBERTON
Docket Number:
INCIDENT NO: 19980400769 CAR
THE ACTOR VIOLATED THE ORDER BY
HAVING CONTACT WITH VICTORIA BARNES AND THAT HE DID HIT HER IN
THE MOUTH AND DID CHOKE HER. SAID ACTS DID REQUIRE MEDICAL
TREATMENT .
ALL OF WHICH WERE AGAINST THE PEACE AND DIGNITY OF THE COMMONWEALTH OF
PENNSYLVANIA AND CONTRARY TO THE ACT OF ASSEMBLY,
OR IN VIOLATION OF 6113 A OF THE ACT OF 23
OR THE ORDINANCE OF
I ask that a warrant 01 arrest or a summons be Issued snd that the accussd be required to answer the charges
I have made. (In order for a warrant of arrest to I..ue, the attached affidavit of probable cau.. muat be
completed and aworn to before the Illulng authority.)
I verify thst the lacts set lorth In this complaint are true and correct to the best 01 my knowledge or Information
and beliel. I certify the complaint has besn properly completed snd verilled, and that thsre Is probable cau..
lor the Issusnce of process. This verification Is made subject to ths penalties of Section 4904 of the Crimea
Code (18 PA. C.S. 4904) relating to unsworn falsification to authorities. Q
Date: Li..;lo.Cjf ~~L ~- C\.
7 (Signature 01 ComplaInant) ~
AND NOW. on this date, I certify amp Int ha e p e y complet and
verllied, and that there Is probable cause for Issuance of pr ess.
n 1t.'M.i!.<1~ 0 I
3.
4.
UUlI'\Q ",I .,
(SEAL)
CARLISLE PD
PROBABLE CAUSE AFFIDAVIT
INCIDENT NUMBER: 19980400769 CAR
COMMONWEALTH VS REGINALD
DATE: 04/17/1998 OTN:
PG2
LAWN
OBERTON
Ii
I ASK THAT A WARRANT OF ARREST BE ISSUED AND THAT THE ACCUSED BE REQUIRED
TO ANSWER THE CHARGE(S) I HAVE MADE IN THE ABOVE AFFIDAVIT.
TO, OR AFFIRM, THE
, AND SIGN IT ON
WITHIN FIDAVIT UPON ~)KNOWLEDGE. INFORMATION
.~U , 19~ ,
WHOSE OFFICE IS THAT OF
C~ () ~
'~A!.
SIGNATURE OF flrF ANT
2 COPIES - DISTRICT JUSTICE
PRINT
1 COPY - BUREAU OF POLICE
CARLISLE PD
PROBABLE CAUSE AFFIDAVIT
INCIDE~r NUMBER: 19980400769 CAR
CHARGE (S) :
23 6113
DATE: 04/17/1998
OTN:
PG 1
IICTS
1
A
INDIRECT CRIMINAL CONTEMPT - CSA1990
COMMONWEALTH VS REGINALD
INFORMATION:
LAWN
OBERTON
VICTORIA BARNES CALLED FROM THE CARLISLE HOSPITAL E.R. TO REPORT
THAT SHE WAS ASSAULTED BY REGINALD OBERTON. BARNES STATED THAT
AT APPROX. 2200 HOURS OBERTON AND HER HAD A PHONE CONVERSATION
THAT TURNED INTO AN ARGUMENT. BEFORE HANGING UP OBERTON TOLD
BARNES THAT HE WAS COMING OVER AND HE WAS GOING TO BEAT HER UP.
.
BARNES STATED THAT A FEW MINUTES HAD PAST UNTIL OBERTON SHOWED
SHOWED UP AT HER HOUSE. OBERTON THREW HER BACK ONTO A BED AND
WITH ONE HAND BEGAN CHOKING HER.
~RIOR TO LEAVING HER HOUSE OBERTON GRABBED A SET OF KEYS AND THE
VICTIMS GLASSES.
MS. BARNES STATED THAT SHE WENT TO 13 7 LINCOLN STREET TO ASK FOR
HER PROPERTY BACK. OBERTON CAME TO THE DOOR AND WAS ASKED ~'OR
THE PROPERTY. OBERTON Pur.LED BARNES INSIDE THE HOUSE. WHILE
INSIDE THE HOUSE HER PICKED BARNES OFF HER FEET AND THREW HER
ONTO THE FLOOR. OBERTON HIT HER IN THE MOUTH, GRABBED HER BY
HER HAIR AND SLAMMED HER HEAD AGAINST A WALL. BARNES STATED
SHE WAS THROWN ONTO THE STAIRWAY. AT THIS POINT THE ASSAULT
HAD STOPPED SHE WENT OUT TO HER CAR AND ATTEMPTED TO DRIVE AWAY.
OBERTON PUSHED HER OVER TO THE PASSENGER SIDE OF THE CAR AND
WOULD NOT LET HER GET OUT.
BARNES STATED THAT THEY DROVE AROUND THE BLOCK DURING WHICH
OBERTON REPEATED TO HER THAT HE WAS SORRY.
.
OBERTON DROVE BARNES BACK TO HER HOUSE. PRIOR TO HIM LEAVING
HE WAS TOLD BY THE VICTIM THAT SHE WAS GOING TO CALL THE POLICE.
OBERTON GAVE HER BACK HER PROPERTY AND LEFT.
.
AT 2336 HOURS I WAS DISPATCHED TO THE CARLISLE HOSPITAL TO MEET
WITH VICTORIA BARNES. I COULD OBSERVE THAT SHE HAD SWELLING AND
CUT, INSIDE AND OUT TO HER LIPS. SHE STATED THAT HER NECK AND
BACK WAS GIVING HER PAIN.
VICTORIA BARNES ADVISED ME THAT SHE HAD AN ACTIVE PROTECTION
ORDER ON FILE AGAINST REGINALD O. OBERTON. THE ORDER SIGNED BY
PRESIDENT JUDGE HAROLD SHEELY ON NOVEMBER 7, 1997.
.
CARLISLE PD
PROBABLE CAUSE AFFIDAVIT
INCIDENT NUMBER: 19980400769 CAR
COMMONWEALTH VS REGINALD
DATE: 04/17/1998 OTN:
PG2
LAWN
OBERTON
"
I ASK THAT A WARRANT OF ARREST BE ISSUED AND THAT THE ACCUSED BE REQUIRED
TO ANSWER THE CHARGE(S) I HAVE MADE IN THE ABOVE AFFIDAVIT.
I SWEAR TO, OR AFFIRM, THE WITHIN ~FIDAVIT UPON ~ KNOWLEDGE, INFORMATION
AND BELl ,AND IGN ON i - .;J 0 ,19'/.(,
BEFO / I WHOSE OFFICE IS 'fifAT OF
~-Il.~'~L4- t..O~ \.
-sIGNATuRE OF AFF!4iT
2 COPIES - DISTRICT JUSTICE
PRINT
1 COPY - BUREAU OF POLICE
Victoria E. Barnes,
Plaintiff
Vo
Reginald O. Oberton,
Defendant
IN THE COURT OF COMMON PLEAS OF
:
CUMBERLAND COUNTY, PENNSYLVANIA
:
: NO. 97-~C~,~CIVIL TERM
:
: PROTECTION FROM ABUSE
TEMPORARY PROTECTION ORDER
AND NOW, this ~/~'day of ~ , 1997,
upon presentation and consideration of the within Petition, and
upon finding that the plaintiff, Victoria E. Barnes, now residing
at 424 North West Street, Carlisle, Cumberland County,
Pennsylvania, is in immediate and present danger of abuse from
the defendant, Reginald O. Oberton, the following Temporary Order
is entered.
The defendant, Reginald O. Oberton, (SSN: unknown and date
of birth: unknown) now residing at 146 West Penn Street,
Carlisle, Cumberland County, Pennsylvania, is hereby enjoined
from physically abusing the plaintiff, Victoria E. Barnes, or
from placing her in fear of abuse.
The defendant is ordered to stay away from the plaintiff's
residence located at 424 North West Street, Carlisle, Cumberland
County, Pennsylvania, a residence which is not owned or leased by
the defendant, and any other residence the plaintiff may
establish.
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 the plaintiff's relatives.
The defendant is enjoined from entering the plaintiff's
place of employment or the school of her minor child.
The defendant is enjoined from removing, damaging,
destroying or selling any property owned solely by the plaintiff.
A violation of 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. §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-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.
A hearing shall be held on this matter on the ~ day of
~~1~, 1997, at J:O0 ~l~.m., in Courtroom No._~
, Cumberland 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 request and without pre-payment
of fees, but service may be accomplished under any applicable
rule of Civil Procedure.
This Order shall be docketed in the office of the
Prothonotary and forwarded to the Sheriff for service. The
Prothonotary shall not send a copy of this Order to the defendant
by mail.
The Mechanicsburg and Carlisle Police Departments will be
provided with certified copies of this Order by the plaintiff's
attorney. This Order shall be enforced by any law enforcement
agency where a violation occurs by arrest for indirect criminal
contempt without warrant upon probable cause that this Order has
been violated, whether or not the violation is committed in the
presence of the police officer. In the event that an arrest is
made under this section, the 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 Court~
Victoria E. Barnes,
Plaintiff
Vo
Reginald O. Oberton,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 97- CIVIL TERM
:
: PROTECTION FROM ABUSE
NOTICE
You have been sued in court. If you wish to defend against the
claims set forth 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 Court and
presenting to the Court your defenses or objections to the claims set
forth against you. You are warned that if you fail to do so the Court
may proceed without you, and a judgment may be entered against you by
the Court without further 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 up to $250.00 to reimburse one of Legal
Services, Inc.'s funding sources for Legal Services Inc.'s
representation of the plaintiff.
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 WITH DISABILITIES ACT OF 1990
The Court of Common 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 court,
please contact our office. All arrangements must be made at least 72
hours prior to any hearing or business before the court. You must
attend the scheduled conference or hearing.
Victoria E. Barnes,
Plaintiff
Reginald O. Oberton,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 97-6~07 CIVIL TERM
PROTECTION FROM ABUSE
PETITION FOR PROTECTION ORDER
RELIEF UNDER THE PROTECTION FROM ABUSE
ACT, 23 Pa.C.S. § 6101 et seq.
A. ABUSE
1. The plaintiff, Victoria E. Barnes, is an adult
individual residing at 424 North West Street, Carlisle,
Cumberland County, Pennsylvania 17013.
2. The defendant, Reginald O. Oberton, (SSN: unknown)(Date
of Birth: unknown), is an adult individual residing at 146 West
Penn Street, Carlisle, Cumberland County, Pennsylvania 17013.
3. The defendant has had an intimate relationship with the
plaintiff.
4. Since approximately the winter of 1997, 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,
and has knowingly engaged in a course of conduct or repeatedly
committed acts toward the plaintiff including following the
plaintiff, without proper authorization, under circumstances
which have placed the plaintiff in reasonable fear of bodily
injury. This has included, but is not limited to, the following
specific instances of abuse:
a. On or about October 14, 1997, the defendant waited
for the plaintiff in the parking lot of her employer
causing her to fear for her safety.
b. In or about August 1997, the defendant hit the
plaintiff, grabbed her, and shoved her up against the
car. The defendant choked the plaintiff until she
almost passed out, hit her body and head with the cast
on his arm causing pain, bruises, and a difficulty in
swallowing.
c. In or about July 1997, the defendant grabbed the
plaintiff, pushed her onto the bed, and hit her several
times on the legs causing swelling and bruising. The
defendant continued to push the plaintiff onto the bed,
slap her, and pull her hair causing bruises.
d. On several occasions since the winter of 1997, the
defendant has shoved, restrained, choked, punched,
kicked, and slapped the plaintiff causing bruises and
scars. The defendant has thrown objects at the
plaintiff, punched walls, and cut the plaintiff's
clothing. On several occasions, the defendant has
attempted to burn her with cigarettes and has
threatened to kill her causing her to fear for her
life.
5. The plaintiff believes and therefore avers that she is
in immediate and present danger of abuse from the defendant and
2
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
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 the
plaintiff's relatives.
8. The plaintiff desires that the defendant be restrained
from entering her place of employment or the school of her minor
child.
9. The plaintiff desires that the defendant be enjoined
from removing, damaging, destroying or selling any property owned
solely by the plaintiff.
B. EXCLUSIVE POSSESSION
I0. The home which the plaintiff is asking the Court to
order the defendant to stay away from is not owned or rented in
the defendant's name.
11. The defendant has his own residence located at 146 West
Penn Street, Carlisle, Pennsylvania.
C. REIMBURSEMENT FOR COST OF CASE
12. The plaintiff asks that the defendant be ordered to pay
$250.00 to reimburse one of Legal Services, Inc.'s funding
sources for the cost of litigating this case.
WHEREFORE, pursuant to the provisions of the "Protection
from Abuse Act" of October 7, 1976, 23 Pa.C.S. § 6101 et seq., as
amended, the plaintiff prays this Honorable Court to grant the
following relief:
A. Grant a Temporary Order pursuant to the
"Protection from Abuse Act:"
1. 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 the plaintiff's relatives.
4. Prohibiting the defendant from entering the
plaintiff's place of employment or school of her
minor child.
5. Prohibiting the defendant from removing,
damaging, destroying or selling property owned
solely by the plaintiff.
6. Ordering the defendant to stay away from the
plaintiff's residence located at 424 North West
Street, Carlisle, Cumberland County, Pennsylvania,
4
and any other residence the plaintiff may
establish.
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. 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 the plaintiff's relatives.
4. Prohibiting the defendant from entering the
plaintiff's place of employment or the school of
her minor child.
5. Prohibiting the defendant from removing,
damaging, destroying or selling property owned
solely by the plaintiff.
6. Ordering the defendant to stay away from the
plaintiff's residence located at 424 North West
Street, Carlisle, Cumberland County, Pennsylvania,
and any other residence the plaintiff may
5
establish.
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 hearing, and that certified copies
of this Petition and Order be delivered to the Mechanicsburg and
Carlisle Police Departments which have jurisdiction to enforce
this Order.
The plaintiff prays for such other relief as may be just and
proper.
Respectfully submitted,
LEGAL SERVICES, INC.v
8 Irvine Row
Carlisle, PA 17013
(717) 243-9400
aintiff
The above-named plaintiff, Victoria E. Barnes, verifies that
the statements made in the above Petition are true and correct.
The plaintiff understands that false statements herein are made
subject to the penalties of 18 Pa.C.S
falsification to authorities.
§ 4904 relating to unsworn
/
B~~ Plaintiff
Victoria E. Barnes,
Plaintiff
Reginald O. Oberton,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
:
: NO. 97-6067 CIVIL TERM
:
: PROTECTION FROM ABUSE
,PROTECTION ORDER
AND NOW, this day of November, 1997, upon
consideration of the Consent Agreement of the parties, the
following Order is entered:
1. The defendant, Reginald O. Oberton, is enjoined from
physically abusing the plaintiff, Victoria E. Barnes, 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 plaintiff's
relatives.
4. The defendant is prohibited from entering the
plaintiff's place of employment or the school of her minor child.
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 424 West North Street, Carlisle,
Cumberland County, Pennsylvania, and any other residence the
plaintiff may establish.
7. The court costs and fees are waived.
8. This Order shall remain in effect for a period of one
year or until modified or terminated by the Court. The Order 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.
9. A violation of 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. §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-residence on the part of the plaintiff and defendant shall not
nullify the provisions of the court order.
10. The Carlisle and Silver Spring Township Police
Departments shall be provided with certified copies 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 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 Court,
- El Shee~'f,'15%esident Judge
Joan Carey -P~t~l(ain 'iff ~'~'~
Attorney for
Reginald O. Oberton.~
Pro Se
Victoria E. Barnes,
Plaintiff
Vo
Reginald O. Oberton,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 97-6067 CIVIL TERM
PROTECTION FROM ABUSE
CONSENT AOREEMENT
This Agreement is entered on this ,5~ day of November,
1997, by the plaintiff, Victoria E. Barnes, and the defendant,
Reginald O. Oberton. The plaintiff 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.
1. The defendant, Reginald O. Oberton, agrees to refrain
from abusing the plaintiff, Victoria E. Barnes, 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
plaintiff and not to harass the plaintiff's relatives.
4. The defendant agrees not to enter the plaintiff's place
of employment or the school of her minor child.
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 plaintiff's
residence located at 424 West North Street, Carlisle, Cumberland
County, Pennsylvania, and any other residence the plaintiff may
establish.
7. The defendant, although entering into this Agreement,
does not admit the allegations made in the Petition.
8. 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
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. 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.
9. Violation of the Protection Order may subject the
defendant to: i) arrest under 23 Pa.C.$. §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 $100.00-$1,000.00;
and iv) civil contempt under 23 Pa.C.S. §6114.1.
~EREFORE, the parties request that a Protection Order be
.~e~ed ~reflect the above terms.
~" ~d E. s, Plaintiff ~ginald O. Oberton, Defendant
~:~r~e~or Pl~ntiff
LEGAL $ERVICE$~ INC.
8 Irvine Row
Carlisle, PA 17013
(717) 243-9400
Victoria E. Barnes,
Plaintiff
Reginald O. Oberton,
Defendant
IN THE COURT OF COMMON PLEAS OF
:
: CUMBERLAND COUNTY, PENNSYLVANIA
:
NO. 97-~CIVIL TERM
:
:
: PROTECTION FROM ABUSE
TEMPORARY PROTECTION ORDER
AND NOW, this 3/~'f-day of ~/~z~ , 1997,
upon presentation and consideration of the within Petition, and
upon finding that the plaintiff, Victoria E. Barnes, now residing
at 424 North West Street, Carlisle, Cumberland County,
Pennsylvania, is in immediate and present danger of abuse from
the defendant, Reginald O. Oberton, the following Temporary Order
is entered.
The defendant, Reginald O. Oberton, (SSN: unknown and date
of birth: unknown) now residing at 146 West Penn Street,
Carlisle, Cumberland County, Pennsylvania, is hereby enjoined
from physically abusing the plaintiff, Victoria E. Barnes, or
from placing her in fear of abuse.
The defendant is ordered to stay away from the plaintiff's
residence located at 424 North West Street, Carlisle, Cumberland
County, Pennsylvania, a residence which is not owned or leased by
the defendant, and any other residence the plaintiff may
establish.
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 the plaintiff's relatives.
The defendant is enjoined from entering the plaintiff's
place of employment or the school of her minor child.
The defendant is enjoined from removing, damaging,
destroying or selling any property owned solely by the plaintiff.
A violation of 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. §6114, punishable by imprisonment up to
six months and a fine of $I00.00-$I,000.00; and iv) civil
contempt under 23 Pa.C.S. §6114.1. 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.
A hearing shall be held on this matter on the ~ day of
.~.Z~J~J~ , 1997, at __?.'tQ~ /O.m., in Courtroom No.
/
, Cumberland 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 request and without pre-payment
of fees, but service may be accomplished under any applicable
rule of Civil Procedure.
This Order shall be docketed in the office of the
Prothonotary and forwarded to the Sheriff for service. The
Prothonotary shall not send a copy of this Order to the defendant
by mail.
The Mechanicsburg and Carlisle Police Departments will be
provided with certified copies of this Order by the plaintiff's
attorney. This Order shall be enforced by any law enforcement
agency where a violation occurs by arrest for indirect criminal
contempt without warrant upon probable cause that this Order has
been violated, whether or not the violation is committed in the
presence of the police officer. In the event that an arrest is
made under this section, the 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 Court,
TRUE COPy FROM RECORD
In Testimony wh
. ere0f, I here unto set ~ tlal~l
aha tl~ s~ of sa,o Cou~ at Carlisle,
Victoria E. Barnes,
Plaintiff
Vo
Reginald O. Oberton,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 97- CIVIL TERM
:
: PROTECTION FROM ABUSE
NOTICE
You have been sued in court. If you wish to defend against the
claims set forth 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 Court and
presenting to the Court your defenses or objections to the claims set
forth against you. You are warned that if you fail to do so the Court
may proceed without you, and a judgment may be entered against you by
the Court without further 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 up to $250.00 to reimburse one of Legal
Services, Inc.'s funding sources for Legal Services Inc.'s
representation of the plaintiff.
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 WITH DISABILITIES ACT OF 1990
The Court of Common 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 court,
please contact our office. All arrangements must be made at least 72
hours prior to any hearing or business before the court. You must
attend the scheduled conference or hearing.
Victoria E. Barnes,
Plaintiff
Reginald O. Oberton,
Defendant
IN THE COURT OF COMMON PLEAS OF
:
CUMBERLAND COUNTY, PENNSYLVANIA
:
: NO. 97- CIVIL TERM
:
: PROTECTION FROM ABUSE
PETITION FOR PROTECTION ORDER
RELIEF UNDER THE PROTECTION FROM ABUSE
ACT, 23 Pa.C.S. § 6101 et seq.
^. ABUSE
1. The plaintiff, Victoria E. Barnes, is an adult
individual residing at 424 North West Street, Carlisle,
Cumberland County, Pennsylvania 17013.
2. The defendant, Reginald O. Oberton, (SSN: unknown)(Date
of Birth: unknown), is an adult individual residing at 146 West
Penn Street, Carlisle, Cumberland County, Pennsylvania 17013.
3. The defendant has had an intimate relationship with the
plaintiff.
4. Since approximately the winter of 1997, 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,
and has knowingly engaged in a course of conduct or repeatedly
committed acts toward the plaintiff including following the
plaintiff, without proper authorization, under circumstances
which have placed the plaintiff in reasonable fear of bodily
injury. This has included, but is not limited to, the following
specific instances of abuse:
a. On or about October 14, 1997, the defendant waited
for the plaintiff in the parking lot of her employer
causing her to fear for her safety.
b. In or about August 1997, the defendant hit the
plaintiff, grabbed her, and shoved her up against the
car. The defendant choked the plaintiff until she
almost passed out, hit her body and head with the cast
on his arm causing pain, bruises, and a difficulty in
swallowing.
c. In or about July 1997, the defendant grabbed the
plaintiff, pushed her onto the bed, and hit her several
times on the legs causing swelling and bruising. The
defendant continued to push the plaintiff onto the bed,
slap her, and pull her hair causing bruises.
d. On several occasions since the winter of 1997, the
defendant has shoved, restrained, choked, punched,
kicked, and slapped the plaintiff causing bruises and
scars. The defendant has thrown objects at the
plaintiff, punched walls, and cut the plaintiff's
clothing. On several occasions, the defendant has
attempted to burn her with cigarettes and has
threatened to kill her causing her to fear for her
life.
5. The plaintiff believes and therefore avers that she is
in immediate and present danger of abuse from the defendant and
2
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
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 the
plaintiff's relatives.
8. The plaintiff desires that the defendant be restrained
from entering her place of employment or the school of her minor
child.
9. The plaintiff desires that the defendant be enjoined
from removing, damaging, destroying or selling any property owned
solely by the plaintiff.
B. EXCLUSIVE POSSESSION
10. The home which the plaintiff is asking the Court to
order the defendant to stay away from is not owned or rented in
the defendant's name.
11. The defendant has his own residence located at 146 West
Penn Street, Carlisle, Pennsylvania.
C. REIMBURSEMENT FOR COST OF CASE
12. The plaintiff asks that the defendant be ordered to pay
$250.00 to reimburse one of Legal Services, Inc.'s funding
sources for the cost of litigating this case.
WHEREFORE, pursuant to the provisions of the "Protection
from Abuse Act" of October 7, 1976, 23 Pa.C.S. § 6101 et seq., as
amended, the plaintiff prays this Honorable Court to grant the
following relief:
A. Grant a Temporary Order pursuant to the
"Protection from Abuse Act:"
1. 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 the plaintiff's relatives.
4. Prohibiting the defendant from entering the
plaintiff's place of employment or school of her
minor child.
5. Prohibiting the defendant from removing,
damaging, destroying or selling property owned
solely by the plaintiff.
6. Ordering the defendant to stay away from the
plaintiff's residence located at 424 North West
Street, Carlisle, Cumberland County, Pennsylvania,
and any other residence the plaintiff may
establish.
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. 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 the plaintiff's relatives.
4. Prohibiting the defendant from entering the
plaintiff's place of employment or the school of
her minor child.
5. Prohibiting the defendant from removing,
damaging, destroying or selling property owned
solely by the plaintiff.
6. Ordering the defendant to stay away from the
plaintiff's residence located at 424 North West
Street, Carlisle, Cumberland County, Pennsylvania,
and any other residence the plaintiff may
establish.
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 hearing, and that certified copies
of this Petition and Order be delivered to the Mechanicsburg and
Carlisle Police Departments which have jurisdiction to enforce
this Order.
The plaintiff prays for such other relief as may be just and
proper.
Respectfully submitted,
8 Irvine Row
Carlisle, PA 17013
(717) 243-9400
ff
The above-named plaintiff, Victoria E. Barnes, verifies that
the statements made in the above Petition are true and correct.
The plaintiff understands that false statements herein are made
subject to the penalties of 18 Pa.C.S § 4904 relating to unsworn
falsification to authorities. ~~,~~~ ~' ~/,/~~,, ~:'
s, Plaintiff
BAIL BOND
OTN DJ No:
CC No: DJ Docket No:
Commonwealth vs. (Defendant Name and Address)
Reginald Lawn Oberton
146 W. Penn St.
Carlisle, PA 17013
qq- &OS V &q' DateofCharge(s): 4/17/98
NEXT COURT ACTION Date/Time/Location
Court of Common Pleas
CHARGE(S): Indirect Criminal Contempt
ADDITIONAL CHARGES MAY EXIST. PLEASE SEE ADDITIONAL CHARGES PAGE.
TYPE(S) OF RELEASE:
E~ ROR
[] Nominal Bail
[] Unsecured Bail [] Nonmonetary Condition(s) (see additional page(s))
[] Monetary Condition(s) in the amount of $
THE CONDITK~, S OF THIS BA~ BOND ARE AS FOLLOWS:
1. The defendadi must appear at'all times required until full and final disposition of the case.
2. The defendant must obey all further orders of the bail authority.
3. The defendant must give written notice to the bail authority, the clerk of courts, the district attorney, and the court bail agency or other designated court bail
officer, of any change of address within 48 hours of the date of the change.
4. The defendant must neither do, nor cause to be done, nor permit to be done on his/her behalf, any act as proscribed by Section 4952 of the Crimes Code
(relating to intimidation of witnesses or victims) or by Section 4953 (relating to retaliation against witnesses or victims), 18 Pa.C.S. §§ 4952,4953.
5. The defendant must refrain from criminal activity.
TYPES OF SECURITY:
[] Cash/Equivalent [] Gov't Bearer Bonds
[] __% Cash [] Surety Bond
TOTAL AMOUNT BAIL SET (IF ANY): $
[] Realty w/in Commonwealth
r-I Realty outside Commonwealth
(see sureties page)
This bond is valid for the entire proceedings and until full and final disposition of
the case including all avenues of direct appeal to the Supreme Court of Pennsylvania.
I AGREE THAT I WILL APPEAR AT ALL SUBSEQUENT PROCEEDINGS AS REQUIRED AND COMPLY WITH ALL THE CONDITIONS OF THE BAIL BOND.
THIS BOND SIGNED ON ~L~.,, ~'~ ~ 19 ~
PENNSYLVANIA
JUDGE OR ISSUING AUTHORITY
ourt or IssuJ~;I. Authorily) ~ (SEAL)
DATE
My commission expires first Monday of January,
PLEASE SEE ATTACHED PAGES FOR ADDITIONAL INFORMATION.
AOPC 414A1-97
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF: CUMBERLAND
Mag. Dist. No.:
09-2-01
DJ Name: Hon.
PAULA P. CORREAL
^ddt,.: EAST WING - COURTHOUSE
1 COURTHOUSE SQUARE
CARLISLE, PA
Telephone: (717) 240-6564 17013-0000
DEFENDANT:
IN FORMA PAUPERIS
AFFIDAVIT/PETITION
VS.
NAME and ADDRE~
I_
Docket No.:
Date Filed:
STATEMENT OF THE PETITIONER
I hereby request that this Court permit me to proceed in forma pauperis (without payment of the filing fee). In
support of this I state the following:
~1~. I am the plantiff in the above matter and because of my financial condition am unable to pay the fee for
filing this action.
r-'J2. I am unable to obtain funds from anyone, including my family and associates, to pay the costs of litigation.
r'-13, i represent that the information below relating to my ability to pay the fees and costs is true and correct:
NAME AND ADDRESS PRESENT EMPLOYER'S NAME AND ADDRESS
~ I AM PRESENTLY UNEMPLOYED.
SALARY OR WAGEB PER MONTH:
INCOME FOR THE PAST 12 MONTHS (CHECK ONE)
1. LESS THAN $20,000 /
THE DATE OF MY LAST EMPLOYMENT WAS:
~--LESS THAN $15,000
-~)ALARY OR WAGES PER IdONTH: 3. LESS THAN $10,000
TTPE OF WORK; 4. LESS THAN $5,000
OTHER INCOME RECEIVED WITHIN THE PAST TWELVE MONTHS: IF NONE, PLEASE STATE "NONE"
OTHER 8ELF-EMPLOYMENT: DIVIDEND~:
PENSION AND ANNUITUES:
SUPPORT PAYMENTS:
Der month D~aUTY PAYMEN3~:
per month PUSUC ASSISTANCE:
SOCIAL SECURITY BENEFITS:
WORKMAN'$ COMPENSATION:
UNEMPLOYMENT COMPENSATION AND ~UPPLEMENTAL BENEFIT8:
OTHER:
Der month
per month
per mo~gh
*IF SUPPORT PAYMENTS ARE NOT CURRENT
CHECK HERE
AOPC 622A-92 PAGE 1 OF 2
Case Name:
Docket Number:
PLEASE CHECK ONE:
Single Separated
OTHER CONTRIBUTIONS TO HOUSEHOLD SUPPORT:Married Divorced
Widowed
t;,~rq{H~=~;.'~) NA~E: ~.~) ~ ['--1 MY ~FL~ (HUSSANO) ~ EMPLOYEn:
EMPLOYER: SALARY OR WAGE6 PER MONTH:
CONTPJ BUTIOIx~ FROM OHII. DP, EN: CONTRIBUT1ON~ FROM pARENTS:
OTHr~ qONTRIBUTK)NS:
PROPERTY OWNED
SAVINGS ACCOUNT:
IF NONE,
pLEASE STATE "NONE"
CERTIFIC..,ATE~ OF
MOTOR VEHICLE: MAKE
yEAR
CO~T AMOUNT OWED:$
STOCKS~BONOS: OTHER
DEBTS AND OBUGATIONS IF NONE, PLEASE STATE "NONE"
MORTGAGE: RENT:
LOANS: / *'~'~"~' ~'~ OTHER:
CH'rLD surroRT: 3
PERSONS DEPENDENT UPON ME FOR SUPPORT
~ ~F~US~ N~E:
NAME: ~E: ~E: ~E:
] OTHER PEP~ON8 - NAME: RELATIONSHIP:
RELATIONSHIP:
NAME:
~t:-I-unde~stand that I have a continuing obligation to inform the Court of improvement in my financial circum-
stances which would permit me to pay the costs incurred herein.
~.1 verify that the statements made in this petition are true and correct. I understand that false statements
herein are made subject to penalties of 18 Pa. C.S. Sec. 4904, relating to unshorn falsification to authorities.
Date: ~ , , '~/' ~.~- - /
My commission expires first Monday of Janua;y, 2000
AOPC 6228-93 PAGE 2 OF 2
, District Justice
SEAL
C(~MMONW'EALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
Mag.Dist. No.: 09201
DJ Name: Hon. PAULA P CORREAL
1 COURTHOUSE SQ
Telephone: CAR_LISLE
717 240 6565
AKA:
REGINALD OBERTON
PA 17013
Registration Number A~nual Sticker Number
I
Complaint Number Complaint Numbers if other Participants
R.S.A.: BM 27 D.O.B.:
ORI NO.: PA0210200
District Attorney's Office Approved
DEFENDANT:
CRIMINAL COMPLAINT AND
PROBABLE CAUSE AFFIDAVIT
COMMONWEALTH OF
PENNSYLVANIA
VS.
NAME and ADDRESS
REGINALD LAWN OBERTON
146 W PENN STREET
CARLISLE PA 17013 0000 00
Docket No.:
Date Filed:
OTN:
OLN Number SID Number
I I
incident Number UCR Number
01 07 1971 $.8.#: 211 54 7234
Disapproved because:
(The District Attorney may require that the complaint, arrest warrant affidavit, or both be approved by the attorney for the Commonwealth pdor to filing.
Pa.R.Cr.P. 107.) When the affiant is not a police officer as defined in Rule 51(C) and the offense(s) charged include(s) a misdemeanor or felony which
does not involve a clear and present danger to any person or the community, the complaint shall be submitted to the attorney for the Commonwealth, who
shall approve or disapprove without unreasonable delay).
(Issue Date)
I, (Name of Affiant) PO THOMA-q L DAY BADGE 2 5
of CARLISLE PD
residing at 53 WEST SOUTH ST CARLISLE PA 17013
do hereby state: (check appropriate area)
1. X I accuse the above named defendant, who lives at the address set forth above or,
I accuse an individual whose name is unknown to me but who is described as
__ I accuse the defendant whose name and popular designation or nickname is unknown to me and whom I
have therefore designated as John Doe
with ~i~l~ti~g~l~T~a~j~l~.mmonwealth of Pennsylvania at: CARLISLE
( Place-Polifica] Subdivision)
in(County) CONBE:R.T.~_ND on or al~t 04 17 1998 2353 HRS
04 17 1998 2200 HRS
Participants were: (if there were participants place their names hare, repeating name of above defendant)
The acts committed by the accused were:
(Set forth a summary of the facts sufficient to advise the defendant of the nature of the offense charged. Neither the evidence nor the statute
allegedly violated need be cited, nor shall a citation of the statute allegedly violated, by itself, be sufficient. In a summary sase, set forth a
citation of the specific section and sub-section of the statute or ordinance allegedly violated).
INDIRECT CRIMINAL CONTEMPT - CSA1990 CTS 1
THE ACTOR DID VIOLATE THE PROTECTION FROM ABUSE ORDER
NUMBER 97-6067
THE ORDER WAS SIGNED BY THE HONORABLE HAROLD E. SHEELY
THE ORDER WAS DATED NOVEMBER 7, 1997
Copy: District Justice Defendant Return of Service Police 4/97wp
Page 2
CRIMINAL COMPLAINT AND
PROBABLE CAUSE AFFIDAVIT
Defendant Name:REGINALD LAWN OBERTON
Docket Number:
INCIDENT NO: 19980400769 CAR
THE ACTOR VIOLATED THE ORDER BY
HAVING CONTACT WITH VICTORIA BARNES AND THAT HE DID HIT }{ER IN
THE MOUTH AND DID CHOKE }{ER. SAID ACTS DID REQUIRE MEDICAL
TREATMENT.
ALL OF WHICH WERE AGAINST THE PEACE AND DIGNITY OF T}{E COMMONWEALTH OF
PENNSYLVANIA AND CONTRARY TO THE ACT OF ASSEMBLY,
OR IN VIOLATION OF 6113 A OF THE ACT OF 23
OR T}{E ORDINANCE OF
3. I ask that a warrant of arrest or a summons be issued and that the accused be required to answer the charges
I have made. (In order for a warrant of arrest to issue, the attached affidavit of probable cause must be
completed and sworn to before the issuing authority.)
4. I verify that the facts set forth in this complaint are true and correct to the best of my knowledge or information
and belief. I certify the complaint has been properly completed and verified, and that there is probable cause
for the issuance of process. This verification is made subject to the penalties of Section 4904 of the Crimes
Code (18 PA. C.S. 4904) relating to unsworn falsification to authorities.
AND NOW, on this date, I certify~int ha~'~ pj~y complet~t)and
verified'andthatthoreispr°bablecausef°rissuance°fprC~'"/~~~~tF'),~.~- ~=.~--0 ,
isterml District) EAL)
~ (;ssuirlg Aut~igty) %..
INCIDENT ~ER:
COMMONWEALTH
CARLISLE PD
PROBABLE CAUSE AFFIDAVIT
19980400769 CAR DATE: 04/17/1998
VS REGINALD LAWN
OTN:
OBERTON
PG 2
I ASK THAT A WARRANT OF ARREST BE ISSUED AND THAT THE ACCUSED BE REQUIRED
TO ANSWER THE CHARGE(S) I HAVE MADE IN THE ABOVE AFFIDAVIT.
I SWEAR TO, OR AFFIRM, THE WITHIN_.AFFIDAVIT UPON M~,KNOWLEDGE, INFORMATION
~, ANo SIaN IT ON /~ ~'~O , 19~¥ ,
~FOR$ ,/ ~ /7 / / WHOSE OFFICE IS THAT OF__ __
j~AW~[TURE & ~ O~ISTRIC~ ~STICE ' gIGNA~E OF ~FI~
PRINT
2 COPIES - DISTRICT JUSTICE 1 COPY - BUREAU OF POLICE
CARLISLE PD
PROBABLE CAUSE AFFIDAVIT
INCIDENT NUMBER: 19980400769 CAR DATE: 04/17/1998 OTN:
CHARGE(S):
23 6113 A INDIRECT CRIMINAL CONTEMPT - CSA1990
PG 1
#CTS
1
COMMO~TH VS REGINALD LAWN OBERTON
INFORMATION:
VICTORIA BARNES CALLED FROM THE CARLISLE HOSPITAL E.R. TO REPORT
THAT SHE WAS ASSAULTED BY REGINALD OBERTON. BARNES STATED THAT
AT APPROX. 2200 HOURS OBERTON AAID HER HAD A PHONE CONVERSATION
THAT TURNED INTO AN ARGUMENT. BEFORE HANGING UP OBERTON TOLD
BARNES THAT HE WAS COMING OVER AND HE WAS GOING TO BEAT HER UP.
BARNES STATED THAT A FEW MINUTES HAD PAST UNTIL OBERTON SHOWED
SHOWED UP AT HER HOUSE. OBERTON THREW HER BACK ONTO A BED AND
WITH ONE HAND BEGAN CHOKING HER.
PRIOR TO LEAVING HER HOUSE OBERTON GRABBED A SET OF KEYS AND THE
VICTIMS GLASSES.
MS. BARNES STATED THAT SHE WENT TO 137 LINCOLN STREET TO ASK FOR
HER PROPERTY BACK. OBERTON CAME TO THE DOOR AND WAS ASKED FOR
THE PROPERTY. OBERTON PULLED BARNES INSIDE THE HOUSE. WHILE
INSIDE THE HOUSE HER PICKED BARNES OFF HER FEET AND THREW HER
ONTO THE FLOOR. OBERTON HIT HER IN THE MOUTH, GRABBED HER BY
HER HAIR AND SLAMMED HER HEAD AGAINST A WALL. BARNES STATED
SHE WAS THROWN ONTO THE STAIRWAY. AT THIS POINT THE ASSAULT
HAD STOPPED SHE WENT OUT TO HER CAR AND ATTEMPTED TO DRIVE AWAY.
OBERTON PUSHED HER OVER TO THE PASSENGER SIDE OF THE CAR AND
WOULD NOT LET HER GET OUT.
BARNES STATED THAT THEY DROVE AROUND THE BLOCK DURING WHICH
OBERTON REPEATED TO HER THAT HE WAS SORRY.
OBERTON DROVE BARNES BACK TO HER HOUSE. PRIOR TO HIM LEAVING
HE WAS TOLD BY THE VICTIM THAT SHE WAS GOING TO CALL THE POLICE.
OBERTON GAVE HER BACK HER PROPERTY AND LEFT.
AT 2336 HOURS I WAS DISPATCHED TO THE CARLISLE HOSPITAL TO MEET
WITH VICTORIA BARNES. I COULD OBSERVE THAT SHE HAD SWELLING AND
CUT, INSIDE AND OUT TO HER LIPS. SHE STATED THAT HER NECK AND
BACK WAS GIVING HER PAIN.
VICTORIA BARNES ADVISED ME THAT SHE HAD AN ACTIVE PROTECTION
ORDER ON FILE AGAINST REGINALD O. OBERTON. THE ORDER SIGNED BY
PRESIDENT JUDGE HAROLD SHEELY ON NOVEMBER 7, 1997.
INCIDENT NUMBER:
COMMONWEALTH
CARLISLE PD
PROBABLE CAUSE AFFIDAVIT
19980400769 CAR DATE: 04/17/1998
VS REGINALD LAWN
OTN:
OBERTON
PG 2
I ASK THAT A WARRANT OF ARREST BE ISSUED AND THAT THE ACCUSED BE REQUIRED
TO ANSWER THE CHARGE (S) I HAVE MADE IN THE ABOVE AFFIDAVIT.
~EFOR~/~~~~,~/ f ) ~// /.n / / WHOSE OFFICE~...~~f.~Q~_~I~ THAT OF
S~E & SEAL OF D~STRICT ~STICE SIGNATURE OF AFFT~NT
PRINT
2 COPIES - DISTRICT JUSTICE 1 COPY - BUREAU OF POLICE
VICTORIA E. BARNES,
Plaintiff
V.
REGINALD O. OBERTON,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
:
:
:
: PROTECTION FROM ABUSE
: NO. 97-6067 CIVIL TERM
IN RE: CONTEMPT
ORDER OF COURT
AND NOW, this 29th day of April, 1998, upon the
request of the District Attorney, disposition on the petition
for indirect criminal contempt is deferred pending the rehearing
to be scheduled at the call of the District Attorney. Pending
said rehearing, Defendant is released on ROR bail on the express
condition that he comply with this Court's order of November 7,
1997.
By the Court,
Edward , J.
John A. Abom, Esquire
Assistant District Attorney
Ellen K. Barry, Esquire ~.~o.
Assistant Public Defender
For the Defendant
CCP
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