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Lori L. Hockenberry,
: INTIIE COURT OF COMMON PLEAS OF
Plainliff
v.
: CUMBERLAND COUNTY, PENNSYLVANIA
NO.97- (.,7/7 CIVIL TERM
James E. Goodjoin, Jr.,
Defendant
PROTECTION FROM ABUSE
TEMPORARY PROTECTION ORDER
i:/o.
AND NOW, this..2- day of December, 1997, upon presentation and consideration of the
within Petition, and upon finding that the plaintiff, Lori L. Hockenberry, now residing at 128 W.
Portland Street, #11, Mechanicsburg, Cumberland COIUlty, Pennsylvania, is in immediate and
present danger of abuse from the defendant, James E. Goodjoin, Jr., the fonowing Temporary
Order is entered.
The defendant, James E. Goodjoin, Jr,. (SSN: unknown and date of birth: 7/28/62) now
residing at 48 W, Main Street, Apartment 6, Mechanicsburg, Cumberland County, Pennsylvania,
is hereby enjoined from physically abusing the plainliff, Lori L. Hockenberry, or placing her in
fear of abuse.
The defendant is ordered to stay away from the plaintiff's residence located at 128 W.
Portland Street, #11, Mechanicsburg, Cumberland County; Pennsylvania, a residence which is
owned by the plaintiff's mother, Karla R. Lear, and any other residence the plainliffmay establish.
The defendant is ordered to refrain from having any direct or indirect contact with the
plainliff including, but not limited to, telephone and written communication.
The defendant is enjoined from harassing and stalking the plainliff and from harassing the
plaintiff's relatives.
The defendant is enjoined from entering the plaintiff's place of employment.
The defendant is enjoined from removing. damaging. destroying or selling any property
owned solely by the plaintiff.
A violation oUhls Order may subject the defendant to: I) arrest under 23 Pa.C.S.
!j6113; II) a private criminal complaint under 23 Pa.C.S. !j6113,1; ill) a charge of Indirect
criminal contempt under 23 Pa.C.S. !j6114, punishable by Imprisonment up to six months
and a ftne of$100.00-$1,000.00; and Iv) civil contempt under 23 Pa.C.S. !j6114.1.
Resumption of co-residence on the part of the plaintiff and defendant shall not nullity the
provisions orthe 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 sha1l be held on this matter on the qtJc day of December, 1997, at
,,: '-IS P.m., in Courtroom No. "_. Cwnberland County Cowthouse, Carlisle, Pennsylvania.
The plaintiff may proceed without pre-payment offees pending fwther order of court.
The Cwnberland 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 fOlwarded to the Sheriff
for service. The Prothonotary shall not send a copy of this Order to the defendant by mail.
The Mechanicsburg and Silver Spring Police Departments will be provided 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 unnecessaIY 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,
I
RLED-OrnCE
OF 111': F:"':"'-~-:}C\~OTARY
97 DEe -5 ,~,H !o: 13
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Lori L. Hockenberry,
IN THE COURT OF COMMON PLEAS OF
Plaintiff
CUMBERLAND COUNlY, PENNSYLVANIA
v.
NO. 97-
CIVll.. TERM
James E. Goodjoin, Jr.,
Defendant
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 omce set forth below to find out where you can get legal help.
COURT ADMINISTRATOR, 4th FLOOR
CUMBERLAND COUNlY COURTIIOUSE
CARliSLE, PENNSYLVANIA 17013
TELEPHONE NUMBER: (717) 240-6200
AMERICANS WIlli DISABILITIES ACT OF 1990
The Court of Common Pleas of Cumberland COlUlty 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.
Lori L. Hockenberry,
Plaintiff
: IN TIIE COURT OF COMMON PLEAS OF
v.
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO.97- 67/7 CIVIL TERM
James E. Goodjoin, Jr.,
Defendant
: PROTECTION FROM ABUSE
PETITION FOR PROTECTION ORDER
RELIEF UNDER TIlE PROTECTION FROM ABUSE
ACT, 23 Pa.C.S. ~ 6101 et seq.
A. ABUSE
1. The plaintiff, Lori L. Hockenberry, is an adult individual residing at 128 W,
Portland Street, #11, Mechanicsburg, Cumberland County. Pennsylvania 17055.
2. The defendant, James E. Goodjoin, Jr., (SSN: unknown)(Date of Birth: 7/28/62),
is an adult individual residing at 48 W. Main Street, Apartment 6, Mechanicsburg, Cumberland
County, Pennsylvania, 17055.
3. The defendant has had an intimate relationship with the plaintiff.
4. Since approximately April 1997, the defendant has attempted to cause and has
intentional1y, knowingly, or recklessly caused bodily injury to the plaintiff, has falsely imprisoned
her pursuant to 18 Pa.C.S. 9 2903, and has knowingly engaged in a course of conduct or
repeatedly committed acts toward the plaintiff 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 November 27, 1997, the defendant grabbed
two folding chairs, threw them on the floor, screamed at the
plaintiff, threatened to break the plaintiff's jaw, and further
threatened to kill her causing her to fear and lock herself in the
bathroom, The plaintiff's mother, who had been at the residence,
called the Mechanicsburg Police who made the defendant leave.
As the defendant was leaving, he screamed at the plaintiff calling
her vile names and telling her she had better bail him out if he went
to jail.
Since November 28, 1997, Wltil the present, the defendant
has repeatedly caned the plaintiff harassing her and threatening her
mother causing her to fear for her safety and the safety of her
mother.
b. On or about October 16, 1997, after the defendant had
repeatedly caned the plaintiff, he showed up at her residence
Wlexpectedly and pushed the door open hitting her in the stomach,
and slapped her across the face. When the plaintiff backed up, the
defendant grabbed her aroWld the throat and shoved her onto a
chair while holding onto her throat. While he held her in the chair,
he threatened to break her jaw and kill her. When the plaintiff got
up from the chair and went to her bedroom, the defendant fonowed
her and threatened to destroy her place if she didn't give him
money, threw pictures, knocked items off of a shelf breaking her
crystal pieces, and knocked other items from the headboard of her
bed causing the plaintiff to continue to fear for her safety. The
defendant threatened to kill the plaintiff if she called the police, The
defendant continued to scream at the plaintiff, threw a glass ashtray
on the floor breaking it, twitched his arm in a way that made the
plaintiff believe he was going to strike her, and then as he walked
toward the door to leave, he knocked a television over onto the
floor.
c, On several different occasions since approximately April
1997, the defendant has locked the plaintiff in his apartment for
hours not allowing her to leave, and repeatedly threatened to break
her jaw and to kill her causing her to fear for her life. On one
occasion, the defendant pulled out a pocket knife and waved it
around while threatening to kill the plaintiff.
S. The plaintiff believes and therefore avers that she is in immediate and present
danger of abuse from the and 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
communica1ions.
7. The plaintiff desires that the defendant be enjoined from harassing and stalking the
plaintiff, and from harassing the plaintiff's relatives,
1-
8.
The plaintiff desires that the defendant be restrained from entering her place of
employment.
9, The plaintiff desires that the defendant be enjoined from removing, damaging,
destroying or selling any property owned solely by the plaintiff.
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 48 W. Main Street, Apartment 6,
Mcchanicsburg. Pennsylvania.
B. LOSSES AND REIMBURSEMENT FOR COST OF CASE
12. The plaintiff has suffered losses as a result of the abuse by the defendant. The
losses are listed on Exlubit A attached.
13. 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.
\VHEREFORE, 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 fonowing relief:
A. Grant a Temporll!)' Order pursuant to the "Protection from Abuse Act:"
1. Ordering the defendant to refrain from abusing the
plaintiff or 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.
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 128 W. Portland Street, #11,
Mechanicsburg, 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:
I, Ordering the defendant to refrain from abusing the
plaintiff or 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.
5. Prohibiting the defendant from removing, damaging,
destroying or seDing property owned solely by the plaintiff.
6. Ordering the defendant to stay away from the
plaintiff's residence located at 128 W. Portland Street, #11,
Mechanicsburg, Cumberland County, Pennsylvania, and any other
residence the plaintiff may establish.
7. Ordering the defendant to reimburse the plaintiff's
out-of-pocket losses suffered as a result of the abuse including but
not limited to the losses listed on the attached sheet marked Exlu'bit
A.
8, 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 Silver Spring Police Departments which
have jwisdiction to enforce this Order.
The plaintiff prays for such other relief as may be just and proper.
Respectfully submitted,
~~tiff
LEGAL SERVICES, INC.
8 Irvine Row
Carlisle, P A 17013
(717) 243-9400
The above-named plaintiff, Lori L. Hockenberry, 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. 9 4904 relating to unsworn falsification to authorities,
Date: /)-";'fl
;J)dk' ~ ~J.l""-~)
Lori L. Hockenbeny, Plain
Lori L. Hockenberry,
: IN THE COURT OF COMMON PLEAS OF
Plaintiff
; CUMBERLAND COUNIY, PENNSYLVANIA
v.
: NO. 97-
CIVIL TERM
James E. Goodjoin, Jr.,
Defendant
; PROTECTION FROM ABUSE
OUT -OF-POCKET LOSSES
The plaintiff requests that the defendant reimburse her out-of-pocket losses, including but
not limited to the foDowing:
Princess House CtyStal Ash Tray
Princess House CtyStal Vanity Set
Princess House Candy Jar and Porcelain Butterflies
Glass Easter Bunny
Lamp
$
55,00
100.00
75.00
10.00
40.00
Total
280.00
Exhibit A
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Lori L. Hockenbeny,
IN THE COURT OF COMM:ON PLEAS OF
Plaintiff
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 97-6717
CIVll- TERM
James E, Goodjoin, Jr.,
Defendant
PROTECTION FROM ABUSE
ORDER FOR CONTINUANCE
AND NOW, this -.lL day of December, 1997, upon consideration of the attached
Motion for Continuance, the hearing scheduled for the 9th day of December, 1997, at 2:45 p,m,
is hereby continued generally, This Order is entered without prejudice to either party to request a
hearing,
The Temporary Protection Order shall remain in effect for one year or until modified or
tenninated by the court.
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.
Certified copies of this Order for Continuance will be provided to the Mechanicsburg and
Silver Spring Police Departments by the plaintiff's attorney,
Joan Carey
Attorney for Plaintiff
I
Edgar B. Bayley, Judge
(1,.n' -,~'".J.. /P../I;t/q'1. >
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James E. Goodjoin, Jr.
Pro So
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FlLED-DFF1CE
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Lori L. Hockenbeny,
: IN THE COURT OF C01\.1M:ON PLEAS OF
Plaintiff
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 97-6717
CIVIL TERM
James E. Goodjoin, Jr"
Defendant
: PROTECTION FROM ABUSE
MOTION FOR CONTINUANCE
The plaintiff, by and through her attorney, moves the Court for an Order generally
continuing the hearing in the above-captioned case on the grounds that:
1, A Temporary Protection Order was issued by this Court on December 5, 1997,
scheduling a hearing for December 9, 1997, at 2:45 p,m.
2, The Cumberland County Sheriff's Department served the defendant with a certified
copy of the Temporary Protection Order and Petition for Protection Order on December 5, 1997.
3. The parties agree that the hearing be generally continued to afford them time to
execute a Consent Agreement
4, The plaintiff requests that the Temporary Protection Order remain in effect for one
year or until modified or terminated by the court after notice and hearing.
5. Certified copies of the Order for Continuance will be delivered to the
Mechanicsburg and Silver Spring Police Departments by the attorney for the plaintiff.
WHEREFORE, the plaintiff requests that the Court grant this Motion and continue this
,-
,
matter generally, and that the Temporary Protection Order remain in effect until further Order of
Court,
Respectfully submitted,
~(&AAt-~
om Carey, Attorney r. Plaintiff
LEGAL SERVICES, INC.
8 Irvine Row
Carlisle, PA 17013
(717) 243-9400
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FiLED-OFFICE
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SHERIFF'S RETURN - REGULAR
CASE NO: 1997-06717 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
HOCKENBERRY LORI L
VS.
GOODJOIN JAMES E JR
DAVID MCKINNEY , Sheriff or Deputy Sheriff of
CUMBERLAND County, Pennsylvania, who being duly sworn according
to law, says, the within PROTECTION FROM ABUSE was served
upon _GOODJOIN JAMES E JR the
defendant, at 1135:00 HOURS, on the 5th day of December
1997 at CUMBERLAND COUNTY PRISON CLAREMONT ROAD
CARLISLE, PA 170~3 . CUMBERLAND
County, Pennsylvania, by handing to JAMES E. GOODJOIN JR.
a true and attested copy of the PROTECTION FROM ABUSE
together with TEMPORARY PROTECTION ORDER NOTICE AND PETITION
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
18.00
3.10
.00
2.00
8~;;j.l!O
So a~nsw: ~~
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R. Thomas Kl1ne, Sher1II
00/00/0000 -
by ~ ~~
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epu y er~r 7J
Sworn and
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subscribed to before
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Lori L. Hockenberry,
IN TIIE COURT OF COMMON PLEAS OF
Plaintiff
CUMBERLAND COUNTY, PENNSYLVANIA
v,
NO. 97-6717
CIVIL TERM
James E, Goodjoin, Jr.,
Defendant
: PROTECTION FROM ABUSE
PROTECTION ORDER
AND NOW, this (t day of Febrwuy, 1998, upon consideration of the Consent
Agreement of the parties, the following Order is entered:
1. The defendant, James E. Goodjoin, Jr., is enjoined from physically abusing the
plaintiff, Lori L. Hockenberry, or from placing her in fear of abuse.
2. The defendant is ordered to refrain from harassing and stalking the plaintiff and
from harassing the plaintiffs relatives.
3. The defendant is prohibited from entering the plaintiffs place of employment.
4. The defendant is prohibited from removing, damaging, destroying or selling any
property owned by the plaintiff.
5. The court costs and fees are waived.
6. lbis 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.
7. A violation of this Order may subject the defendant to: i) arrest under 23 Pa,C.S.
S6113; ii) a private criminal complaint under 23 Pa.C,S. S6113,1; ill) a charge of indirect criminal
contempt under 23 Pa.C.S. S6114, 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. Reswnption of co-
residence on the part of the plaintiff and defendant shall not nullifY the provisions of the court
order.
8, The Mechanicsburg and Silver Spring 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 bcen 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)., ,7J
By~~
Edgar B. Ba , dge
Joan Carey
Attorney for Plaintiff
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James E. Goodjoin, Jr.
Pro Se
FILED-OFFICE
QF"T'dE 'PROTHOhJOTARY
98 FEB 19 AM 8: 09
CUf'lj8E~L/:"i~). COUNTY
PENi'i.JSYL}~\i'J!A
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Lori L. Hockenbeny,
: IN THE COURT OF COMMON PLEAS OF
PIainliff
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 97-6717
CIVIL TERM
James E. Goodjoin, Jr.,
Defendant
: PROTECTION FROM ABUSE
CONSENT AGREEMENT
This Agreement is entered on Ibis ~daY Of~, by the plaintiff, Lori L.
Hockenbeny, and the defendant, James E, Goodjoin, Jr.. The plaintiff is represented by Joan
Carey of LEGAL SERVICES, INC.; the defendant is unrepresented but is aware ofhis right to
have an attorney. The parties agree that the fonowing may be entered as an Order of Court.
1. The defendant, James E. Goodjoin, Jr., agrees to refrain from abusing the plaintiff,
Lori L. Hockenberry, or from placing her in fear of abuse.
2. The defendant agrees not to harass and stalk the plaintiff and not to harass the
I'laintifPs relatives.
3. The defendant agrees not to enter the plaintiff's place of employment.
4. The defendant agrees not to remove, damage, destroy, or sen any property owned
by the plaintiff.
S, The defendant, although entering into Ibis Agreement, does not admit the
allegations made in the Petition.
6. The defendant Wlderlltands 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 hann to the plaintiff. The defendant Wlderlltands that Ibis
"
,
Order will be enforceable in the same manner as the Court's prior Temporary Protection Order
entered in this case.
7. Violation of the Protection Order may subject the defendant to: i) arrest under 23
Pa.C,S. ~61l3; ii) a private criminal complaint under 23 Pa.C,S. ~61l3.1; ill) a charge of indirect
criminal contempt under 23 Pa.C.S. ~6114, punishable by imprisonment up to six months and a
fine ofSlOO.OO-$I,OOO.OO; and iv) civil contempt under 23 Pa.C.S. ~61l4.1.
WHEREFORE, the parties request that a Protection Order be entered to reflect the above
tcnns.
y)tu. j(, /y{(,J,.uk<'~l, )
Lori L. Hockenberry, PlaliI.tiff
~~~
LEGAL SERVICES, INC,
8 Irvine Row
Carlisle, PA 17013
(717) 243-9400
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