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JANELLE MARIE ROUSH,
Plalntitl'
IN THE COURT or COMMON PLEAS OF
CUMBERLAND COUNTY, "ENNSYLV ANIA
v,
NO, ()R. /!.(.{/
,,' CIVIL TERM
JOSEPH MICHAEL J>AVUCSKO,
Defendunt
PROTECTION FROM ABUSE
TEMPORARV PROTECTION ORDER
AND NOW, this:)!!: day of Murch, 1998, upon pres\mtation and consideration of the
within Petition, and upon tinding that the plaintilT, Janelle Maric Roush, now rcsiding at 871 Old
Silver Spring Road, Mechanicsburg, Cumberlund County, Pennsylvania, is in immediate and
present danger of abuse from the defendant, Joseph Michael Pavucsko, the following Temporary
Order is entered,
The defendant, Joseph Michael Pavucsko, (SSN: Unknown)(DOB: 12/25/70), is an adult
individual whose last known residcnce was 49 Sharon Road, Enola, Cumberland County,
Pennsylvania, 17025 (the home of his purtmts, Shirley and Francis Pavucsko) is hereby enjoined
from physically abusing the plaintiff, Janelle Marie Roush, or from placing her in fear of abuse,
The defendant is ordered to stay away from the plaintitl's residence located at 871 Old
Silver Spring Road, Mechanicsburg, Cumberland County, Pennsylvania, a residence whieh is
leased by the plaintiff and her roommate, and is ordered to stay away from any residence the
plaintilT may in the future establish for herself
The defendant is ordered to refrain from having any direct or indirect contact with the
plaintilTincluding, but not Iimitcd to, telephone and written communications,
The defendant is enjoined trom hurussing and stalking the plaintiff and from harassing her
relatives,
The defendant is enjoincd from entcring the plaintitl's place of cmployment.
The defendant is enjoined from damaging or destroying any properlY owned by the
plaintlll
A violation of this Order may subject the defeudant to: i) arl'est under 23 Pa.e.S.
16113; II) a private criminal complaint under 23 Pa.C.S. 16113.1; Iii) a charge of indirect
criminal contempt under 23 PIt.C.S. 16114, punishable by imprisonment up to S;ll months
and a nne of 5100.00-51,000.00; and Iv) civil contempt under 23 Pa.C.S.16\ 14,1.
This Order shall remain in efTect 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 an
act of abuse or has enguged in a pattern or practice thut indicates risk of hurm to the plaintiff, I
A HEARING SHALL BE HELD ON TillS MATTER ON (, I' DAY OF D~{Jj
,1998. AT _ '~. I,) f-.M., IN COURTROOM NO,....L.. OF THE CUMBERLAND
COUNTY COlJRTHOllSE. CARLISLE, PENNSYLVANIA,
The plaintiff may proceed without pre-payment of fees pending u further order after the
healing,
The Cumberland County Sheriffs Department shall attempt to make service ut the
plaintiffs request and without pre-payment of fees, but selvice 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 und Carlisle Police Departments shall be provided with certified
copies of this Order by the plaintiffs attorney, This Order shall be enforced by any law
enforcement agency where u 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 an-est is made, under this
section, the defendant shall be taken without llllnecessary delay before the eourt that issued the
JANELLE MARIE ROUSH,
Plaintil1'
IN nm COURT OF COMMON PLEAS OF
CUMllERLAND COUNTY, PENNSYLVANIA
v.
NO. 98-
CIVIL TERM
JOSEPH MICHAEL P A VUCSKO,
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, Any Protection Order granted by a Conrt may be considered in any subsequent
domestic relations proceedings, including custody actions.
I"EES AND COSTS
If the case goes to hearing and the judge grants u 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 have the right to be represented by counsel. You should take this paper to your
lawyer at once. If you do not have II lawyer or cannot afford one. go to or telephone the
office set forth below to find out where you can get legal help.
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PENNSYLVANIA 17013
TELEPHONE NUMBER (717) 249-3166 or TOLL FREE: 1-800-990-9108
FAX: (717) 249-2663
AMERICANS WITII DISABILITIES ACT OF 1990
The Court of Common Pleas of Cumberlund County is required by law to comply with tbe
Americans with Disabilities Act of 1990, For information about accessible facilities and
reasonable accommodations uvailablc to disabled individuals having business before the court;
. please contaet our oflice, All arrangements must be made at least 72 hours prior to any hearing
or business before the court.
JANELLE MARIE ROUSH,
Plainlill'
IN THE COURT OF COMMON PLEAS OF
v,
CUMBERLAND COUNTY, PENNSYLVANIA
JOSEPH MICHAEL PAVUCSKO,
De/endant
NO, 98./(,~'L________ CIVIL TERM
PROTECTION FROM ABUSE
PETITION FOR PROTECTION ORDER
RELIEF UNDER '1'111\ PRon;r:T10N F'ROM ABUSE ACT
23 Pa,C.S. ~6101 et seq.
A. ABl1SE
I. The plaintiff, Janelle Marie Roush, is an adult individual residing a/ 871 Old Silver
Spring Road, Mechanicsburg, Cumberland County, Pennsylvania 17055,
2. The de/endant, Joseph Miehuel Pavucsko, (SSN: Unknown)(DOB: 12/25170), is
an adult individual whose last known rcsidenee was 49 Sharon Road, Enola, Cumberland County,
Pennsylvania, 17025, the homc of his parents, Shirley and Francis Pavucsko,
3, The defendant has had an intimate relationship with thc plaintiff.
4, Since approximately Januury 1998 , the defendant hus knowingly engaged in a
course of conduct or repeatedly committed acts toward the plaintitr including following the
plaintiff, without proper authorization, under circumstances which have placed the plaintiff in
reasonable fear of bodily i1~ury, This has included, but is not limited to, the following specific
instances of abuse:
a) On or about March 9, J 998, the defendant telephoned the plaintiff at her
residence approximately five times after he had been verbally warned by Detective
Bock of the Mechanicsburg Police Department earlier that day not to have any
further contact with the plaintiff, The plaintiff hung up on the defendant the first
fOllr times, During the Iifih telephone call the defendant begged the plaintiff not to
pursue the criminal investigation ol'the Murch II, 19911, Incident against him saying,
""1.1 never do anything to you again," exacerbating the pluintil1's fear thr her
safety.
b) On or about March II, I 'J'18, an intruder entered the pluintil1" s upartment
and destroyed some of her personal possessions, The plaintitl' has reason to
believe that it wus the defendant who entered her upurtment. The incident wus
reported to tho Meehanicsblll'g J'olice Depart,ment. Dl,tective Boch of the
Mechanicsburg Police Department is conducting u criminal investigation into the
matter and interviewed the detendant on March 9, 1998, us a sllspect, At thut time
Detective Bock udvised the detendantthut he wus not to huve further contact with
the plllintitf
c) In or about early to mid-February 1998, the defendant threatened to kill
himself during a telephone conversation with the plaintiff,
d) On or about February 17, 1998, the plaintiff returned from a trip out-ot:
state and found a message on her voice mail at work from the defendant telling her
that he knew where she hud gone, saying that she wus with her new boyfriend, and
accusing her of sleeping with him,
e) On or allout January 31, 1998, the plaintiff awakened when she heard the
defendant's car drive through the parking lot of her apartment and saw him near
her boyfriend's car which was parked in front of the apartment. The plaintiff,
coneemed that the defendant was vandalizing her boytliend's vehicle, went
downstairs, opened the front door, und asked him what he was doing. When the
defendant starled to come towards the door, the plaintiff tried to shut it, but he
pushed the door open and threatened to kill her boyfriend who was upstairs in the
bedroom, The plaintiff tried to prevent the defendant from going upstairs, but he
picked her up and said, "You're going with me," The plaintiff struggled with the
defendant, who put hcr down and ran up thc stairs to her bcdroom where her
boyfriend sat on the bed, The defendunt jumped on the boyfriend's back, punched
him repeutedly, called the plaintiff names, und heud-bulled the boyfriend in the
I(lrehead causing a lucerntion, The plaintill' telephoned the police fill' help, The
defendunt len the plaintiffs residence betilrl' the police arrived.
f) The Mcchunksburg Police huve advised the plaintill' and Legal Services,
Inc, stall'thut they are concerned for her safety as the defendunt has a history of
stalking at least one other woman in their service areu, The pluintill' only found
out about the defendunt's history of stalking uncI' reporting hm' own problems with
him to the police, The plaintiff fears for her safety btlcause the defendant has
continued to harass und stalk her and the abusive behavior has escaluted,
5, The plaintill' believes and therefore uvers that she is in immediate and present
danger of abuse from the defendunt und that she is in need of protectionlrom such abuse,
6. The plaintiff' desires that the defendant be prohibited from having any direct or
indirect contact with the plaintill' including, but not limited to, telephone and wliUen
eommunications,
7.
plaintiff,
8.
The plaintill'desires that the defendant be enjoined from harassing and stalking the
The plaintill' desires that the defendant be restrained from entering her place of
employment.
9, The plaintill'desires that the defendant be enjoined Irom damaging or destroying
any property owned jointly by the parties or owned by the plaintiff,
8. .;XCLlISIVt; POSSt;SSION
10, The aplu1menl at 871 Old Silvor Spring Road. Mechunicsburg. Cumberland
County, I'onnsylvania. from which the plaintiff' is usking the Court to order the defendant to Sluy
away from is rellted in thc numes of Junelle Murie ROllsh and Amy Duvis, und the defendant has
never resided there,
L.l,;OSSt:S AND REIMBllRSEMENT FOR COST OF CASt:
II, The plaintiff' hus sullbred losses us u result of the incident which oceured on or
about March 8, 1998. The losses ure listed on Exhibit A uttached,
12. The plaintiff asks that the defendant be ordered to pay $25000 to Cumberland
County, one of I,egal Services, Inc, 's Ilmding sources as reimbursement for the cost of litigating
this case, and that the defendant be assessed the $25.00 surcharge and any court costs if the case
goes to heari ng,
WIIEREFORE, pursuant to the provisions of the "Protection from Abuse Act" of October
7,1976,23 P,S. *6101 et ~!'q" 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:"
I, Ordering the delendant to refrnin from abusing the plaintiff or from
placing her in feuI' of abuse,
2, Ordering the defendant to refrain from having any direct or indirect
contact with the plaintiff including, but not limited to, telephonli' and
written communications,
3, Ordering the defendant to refhlir. Irom harassing and stalking the
plaintiff and from harassing her relutives,
4, Prohibiting the delendant from entering the plaintifl's place of
employment.
5, Prohibiting thc dclcndunt Irom damuging 01' dcstroying property
owned by tilt) plaintill',
6, Ordcring the delcndunt to stay uwuy from the plaint ill's residence
located at 871 Old Silver Spring Road, Mechanisburg, Cumberland
County, Pennsylvaniu, which the parties huve never shared, and lrom any
residence thc plaintilf muy in the l\tture establish for herself
8, Schedule a hearing in accordance with lhe provisions of the
"Protection from Abuse Act," and. after such hearing. enter an order to be in etTect for a
period of one year:
I, Ordering the defendant to relrain Irom abusing the plaintiff 01' Ii-om
placing her in fear of abuse,
2, Ordering the defendant to refruin from having any direct or indirect
contact with the plaintiff including, but not limited to, telephone and
written communications,
3, Ordering the delendant to refrain from harassing and stalking the
plaintiff and tI'om harassing her relatives,
4, Prohibiting the defendant from entering the plaintiffs place of
employment.
5, Prohibiting the defendant from damaging or destl'Oying property
owned by the pluintiff,
6, Ordering the defendant to stay away from the plaintiffs residence
located at 871 Old Silver Spring Road, Mechanicsburg, Cumberland
County, Pennsylvania, which the parties have never shared, and ordering
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JANELLE MARIE ROUSH,
Plainlifl'
IN HIE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v,
NO, 98-1664 CIVIL TERM
JOSEPH MICHAEL PAVUCSKO,
Defendant
PROTECTION FROM ABUSE
OTECTION ORDER
AND NOW, this 1, , day of April, 1998, upon consideration of the Consent Agreement
of the parties, the lollowing Ordcr is cntered
I, Thc dcfcndunt, Joseph Michael Pavucsko, is enjoined from physically abusing the
plaintill: Janelle Marie Roush, or from pludng hcr in fear of abuse,
2, Thc dcfendunt is enjoined from huving any direct or indircct contuct with the
plaintiff including, but not limited to, telephone and written communications,
), The defendant is ordcred to refrain from harassing and stalking the plaintiff and
from harassing her relatives,
4, The defendant is prohibited from entering the plaintill's place of employment.
S. The defendant is prohibited lrom dumaging or dcstroying any property owned by
the plaintilf.
6. The defendant is ordered to stay away from the plaintift's residence located at 871
Old Silver Spring Roud, Meehanicsburg, Cumbcrland County, Pennsylvania. which the parties
have never shared, and is ordcred to stay away from any residence the plaintiff may in the future
establish lor herself.
7. Court costs and fces am waived,
8, This Order shull remain in elleet for a period of onc (1) year and can be extended
beyond that time if the Court finds that the defendant has committed an act of abuse or has
engagcd in a pattern or practice that indicatcs risk of harm to the plaintiff, This Or~er shall be
JANELLE MARIE ROUSH,
l'laintill'
IN TIlE COURT OF COMMON PLEAS OF
v,
CUMBERLAND COUNTY,PENNSYLVANIA
JOSEPH MICHAEL I'AVUCSKO,
Defendant
NO. 911-1664 CIVIL TERM
PROTECTION FROM ABUSE
CONSENT AGREEMENT
This Agrcc/llent is cntcrcd on this G,/l.duy of April, 1998, by the plnintill; Janelle Maric
Roush, and the defcndant, Joscph Michacl Pavlle!;ko Thc pluintitl'is represented by Joan Carey
of LEGAL SERVICES, INC; thc dcfendant is represent cd by John F. Lyons, Attorney at Law,
Thc parties agrcc that thc fbllowing muy bc entercd as an Order ofCou!1,
I, The dcfcndant, Joseph l\1iehucl PuvlIcsko, agrccs to rctrain from abusing thc
plaintiff. Janelle Marie Roush, Of' from plucing her in fear of abuse,
2. The dcfendant agrees not to have any direct or indircct contnct with the plaintiff
including, hut not limited to, telephone and written communications,
J. The defendant agrees not to harass and stalk the plaintiff and not to harass her
relatives,
4. Tile defendant agrces not to cnter the plaintitl's placc of employment.
S, The defendant ugrees not to damage or destroy any propcrty owned by the
plaintiff
6. The defendant agrees to stay away from the plaintill's rcsidence located at 871 Old
Silver Spring Road, Mechanicsburg, Cumberland County, Pennsylvania, which the parties have
never shared, and agrces to stay away from any residencc the plaintiff may in the future establish
for herself
7, The defendant, although entering into this Agreement, does not admit the
allegations /llade in thc Petition,
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