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6. Defendant shall cooperate in setting a time when Plaintiff and a neutral party can
return to the former joint residence at SI Ballpark Drive, Gardners, PA 17324 wlthoutlhe
Defendant being present, in order for Plaintiff to remove her personal possessions. Such time
will be scheduled only through contact between Plaintiff's counsel and Defendant or Defendant's
counsel. Defendant may have a neutral third party present at the residence during this time.
7. Defendant shall temporarily relinquish to the sheriff all firearms in his possession
or control.
8. A violation oflhe Order may su~iect the Defendant to: i) arrest under 23 Pa.C,S.
~6113; Ii) a private criminal complaint under 23 Pa.C,S, ~6113.1; ili) a charge of indirect
criminal contempt under 23 Pa.C.S. ~6114, punishable by imprisonment lip to six months and
a fine of $100.00-$1,000,00; and Iv) civil contempt lindeI' 23 Pa.C.S, ~6114.1.
9, Resumption of co-residence on the part of the Plaintiff and Defendant shall not
nullify the provisions of the court order.
10. A hearing shall be held in this mailer on the3/1d day of (~' (', 1998 al ;<i.{;"
in Courtroom No. I, Cumberland County Courthouse, Carlisle, Pennsylvania. Defendant is
hereby informed that he has the right to be represented by counsel. DEFENDANT IS
FURTHER INFORMED THAT ANY PROTECTION ORDER MAY BE CONSIDERED IN
ANY SUBSEQUENT DOMESTIC RELATIONS PROCEEDING, INCLUDING A CHILD-
CUSTODY PROCEEDING.
II. The Carlisle Police Department shall be provided with a certified copy of this
Order by the Plaintiff's allomey. 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 nollhe violation is committed in the presence
SHAWNTA M. BAKER,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION -LAW
IN PROTECTION FROM ABUSE
KEITH J. BOYER,
Defendant
NO, 98- / 'lvv CIVIL TERM
fE.Tl'flOl'1FOR PROTECTION FROM ABUSE
Plaintiff, Shawnta M. Baker, through her counsel, the Family Law CHnic, respectfully
represents as follows:
1. Plaintiff is an adult individual who is residing at a confidential location in
Cumberland County, Pennsylvania.
2. Defendant, Keith J. Boyer, is an adult individual who is residing at 51 Ballpark
Drive, Gardners, Cumberland County, Pennsylvania 17324.
3. Plaintiff and Defendant are former sexual partners.
4. Defendant has abused Plaintiff as that term is defined at 23 Pa.C.S,A. ~6101 el
seq.. This has included but is not limited to the following instances of abuse.
Defendant sarcastically remarked to Plaintiff, "I hope you don't fall down the steps," and
a. On March 24, 1998, at appl'Oximately 10:30 during an argument,
Defendant proceeded to push Plaintiff down a stairway, causing her to fear imminent bodily
injury.
into Plainlifrs chest and slapped Plaintifrs face causing her substantial pain. Defendant aiso
b. On the same evening, Defendant intentionally shoved an electric griddle
pushed a sandwich maker into the chin of the Plaintiff causing her substantial pain. Plaintiff
I. "
then pushed the appliance into the Defendant's chest in order to escape and avoid further abuse.
The Pennsylvania State Police arrested Plaintiff for simple assault when they responded to the
domestic dispute. Proceedings are pending on this charge and Plainliff denies inflicting any
alleged injury to Defendant's face. Plainllff believes and avers that the injury to Defendant's
face was self inflicted.
c, On March 17, 1998, during a dispute Defendant threatened Plaintiff that
he would "take care of her" and warned Plaintiff to "watch her back," thereby placing Plaintiff
in fear of death or serious bodily injury. "
d. On other occasions, Defendant has threatened to shoot Plaintiff with
weapons in his possession. Plaintiff also feared leaving Defendant because he slated to her that
"if he can't have her, then nobody else can." Each of these threats caused Plaintiff to fear death
or serious bodily injury.
e. Finally, on numerous occasions, Defendant has punched Plaintiff's arms
and kicked Plaintiff's legs, causing her substantial pain.
5. Plaintiff believes and therefore avers that she is in immediate and present danger
of serious abuse from Defendant and that she is in need of protection from abuse.
WHEREFORE, pursuant to the provisions of the "Protection From Abuse Act" 23
Pa.C.S.A. ~6101 et seq., Plaintiff prays this Court to grant the following relief:
A. Grant a Temporary Order as follows:
1) Defendant is to refrain from abusing the petitioner or minor child.
2) Defendant is enjoined from harassing and stalking the petitioner and from
harassing her relatives, specifically her children, Ashley Junkins, Mariah Stains, and Brianna
Stains, and Plalntiff'sex-husbafld, Troy Junkins, since Ashley will temporarily be residing with
-',,+J
Mr. Junkins.
3) Defendant shall refnin from damaging or destroying any of Plaintiff's personal
property.
4) Defendant shall cooperate in setting a time when Plaintiff and a neutral party can
retum to 51 Ballpark Drive, Gardeners, PA 17324 without the Defendant being present, in order
for Plaintiff to remove her personal possessions. Such time will be scheduled by Plaintiff's
counsel and Defendant or Defendant's counsel. Defendant may have a neutral third party
present at the residence during this time.
5) Defendant is prohibited from having any contact with the Plaintiff, including, but
not limited to entering her place of employment.
6) Defendant shall temporarily relinquish to the sheriff the respondent's weapons,
including, but not limited to approximately 5 shotguns and I handgun which have been used or
threatened in an incident of abuse.
7) Defendant shall pay the administrative costs and fees required for filing the
Petition.
8) Any such other relief as the Court deems appropriate and just.
B. Schr.dule a plenary hearing and enter an order against the Defendant, to be in
effect fol' one year:
1) Directing Defendant to refrain from abusing the Plaintiff.
2) Prohibiting Defendant from having any contact with the Piaintiff, including, but
not limited to entering her place of employment, and from harassing the petitioner or petitioner's
relatives or minor children.
3) Any such other relief as the Court deems appropriate and just.
This Petition is respectfully submilled, this 27th day of March 1998 by The Pamlly Law
Clinic.
~{J/ ~ It/lit!(
Brad E. Harker
'"' ,"",I,.rem.
Katherine .' Pearson
SUPERVISING A TIORNEY
Donald Marrilz
STAPF ATIORNEY
,
FAMILY LAW CLINIC
45 North Piu Street
Carlisle, PA 17013
(717) 243-2966
Fax: (717) 243..3639
YERIFICATIO~
Understanding that the making of any false statement would subject me to the penaltles
of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities, I verify that the
statements made in this Petition are true and correct to the best of my knowledge and bellef.
3'bu/cl1 c~L.v-
Shawnta M. Baker,
Plaintiff
Dated: Maroh 27, 1998
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(\{~~' APR Q 1 1998.
~"
SHAWNTA M. BAKER,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION. LAW IN
: PROTECTION FROM ABUSE
v.
KEITH J. BOYER,
Defendant
: NO. 98,1700 CIVIL TERM
OR{)ER
AND NOW, this z..,d. day of April, 1998, upon presentation and consideration of
the within Motion, it Is ordered that the hearing in this matter scheduled for 8:45 a.m. on April
3, 1998 as set forth in the Temporary Protective Order of March 27, 1998 shall be continued
generally, at the call of either party. The Temporary Protection Order of March 27, 1998, as
modified by the Order of April -L.._, 1998 allowing contact between the parties for the
purpose of settlement, shall remain in full force and effect.
By the Court,
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1h1. Motl'" In ,""'" ,. re'I"',',lIy "bmil"", ,hi. h' "'y of ,pdl I'" bY '\'bO
~~I
Brad E. Harker
~Jll'wre
Katherine C. pearson
SUPERVISING ATtORNEY
Donald Marotz
ST AFF ATtORNEY
Family LaW Clinic.
.,
FAMILY lAW CLINIC
45 North Pitt Street
Carlisle, PA \7013
(7\7) 243-2968
Fax: (717) 243-3639
YER1FlCA'11.0N
U.d"....'.. "'" ,b' ...",.. 0' ony ,.", .....""'" _Id "bl<Ol ... In ,\10 ....11...
o,IB ...e.s. "",... 4904, re""" In ,,,_ f..Ift"'''' " .."",\II", I ,,,lfy \bot ..
....."""'. "'" ,. ,b" Mot'OO In '10'" '" "'" '" ",- " ,'" "'" 0' my ,,,,,,""'0 ""
belief.
3;,.//J;llli IUrr VI; oA"i'.1/
Shawnta M. Baker;
Plaintiff
Dated: April 1. 1998
" , ,~ ."\,, ~
SHAWNTA M. BAKER,
PlaintJff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: CIVIL ACTION - LAW
: PROTEC'TION FROM ABUSE
KEITH 1. BOYER,
Defendant
: NO. 98- /'7( <>
NOTICE
CIVIL TERM
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 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 ANn 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 attorney fees to the Family Law
Clinic for its 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.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania 17013
(717) 249-3166
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 mllst attend the scheduled conference or hearing.
S'HAWNTA M. BAKER,
Plaintiff
IN THE COURT OF l.lJMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v,
Crvn, ACTION -LAW
IN PROTECTION FROM ABUSE
KEITH 1. BOYER,
Defendant
NO, 98. I IUD
CIVIL TERM
P,KTITION FOR PROtECTION FROM ABUSE
Plaintiff, Shawnta M. Baker, through her Counsel, the Family Law Clinic, respectfully
represents as follows:
I. Plaintiff is an adult individual who is residing at a confidential location in
Cumberland County, Pennsylvania,
2. Defendant, Keith 1. Boyer, is an adult individual who is residing at 51 Ballpark
Drive, Gardners, Cumberland County, Pennsylvania 17324.
3, Plaintiff and Defendant are former sexual panners.
4. Defendant has abused Plaintiff as that term is defined at 23 Pa.C.S.A. 16101 et
seq.. This has included but is not limited to the following instances of abUSe.
Defendant sarcastically remarked to Plaintiff, "I hope you don't fall down the steps," and
a. On March 24, 1998, at approximately 10:30 during an argument,
Defendant proceeded to push Plaintiff down a stairway, causing her to fear imminent bodily
injury.
into Plaintiff's chest and slapped Plaintiff's face causing her substantial pain. Defendant also
b, On the same evening, Defendant intentionally shoved an electric griddle
pushed a sandwich maker into the chin of the Plaintiff causing her substantial pain, Plaintiff
then pushed the appliance into the Defendant's chest in ord"r to escape and avoid further abuse.
The Pennsylvania Slate Pollce arrested Plaintiff for simple assault when they responded 10 the
domestic dispute. Proceedings are pending on this charge and Plaintiff denies inflicting any
alleged injury to Defendant's face. Plaintiff believes and avers that the injury to Defendant's
face was self inflicted.
c. On March 17, 1998, during a dispute Defendant threatened Plaintiff that
he would "take care of her" and warned Plaintiff to "watch her back," thereby placing Plaintiff
in fear of death or serious bodily injury."
d. On other occasions, Defendant has threatened to shoot Plaintiff with
weapons in his possession. Plaintiff also feared leaving Defendant because he stated to her that
"if he can't have her, then nobody else can." Each of these threats caused Plaintiff to fear death
or serious bodily injury.
e. Finally, on numerous occasions. Defendant has punched Plaintiff's arms
and kicked Plaintiff's legs, causing her SUbstantial pain.
5. Plaintiff believes and therefore avers that she is in immediate and present danger
of serious abuse from Defendant and that she is in need of protection from abuse.
WHEREFORE, pursuant to the Provisions of the "Protection From Abuse Act" 23
Pa.C.S.A. ~6101 et seq., Plaintiff prays this Court to grant the following relief:
A. Grant a Temporary Order as follows:
1) Defendant is to refrain from abusing the petitioner or minor child.
2) Defendant is enjoined from harassing and stalking the petitioner and from
harassing her relatives, specifically her children, Ashley Junkins, Mariah Stains, and Brianna
Stains, and Plaintiff's ex-husband, Troy Junkins, since Ashley will temporarily be residing with
Mr. Junkins.
3) Defendant shall refrain from damaging or destroying any of Plaintifrs personal
property.
4) Defendant shall cooperate in selting a time when Plaintiff and a neutral party can
return to 51 Ballpark Drive, Gardeners, PA 17:124 wlthoulthe Defendant being present, In order
for Plaintiff to remove her personal possessions. Such time will be scheduled by Plainlifrs
counsel and Defendant or Defendant's counsel. Defendant may have a neutral third party
present at the residence during this lime.
5) Defendant is prohibited from having any contact with the Plaintiff, including, but
not limited to entering her place of employment.
6) Defendant shall temporarily relinquish to the sheriff the respondent's weapons,
including, but not limited to approximately 5 shotguns and I handgun which have been used or
threatened in an incident of abuse.
7) Defendant shall pay the administrative costs and fees required for filing the
Petition.
8) Any such other relief as the Court deems appropriate and just.
B. Schedule a plenary hearing and el1\er an order against the Defendant, to be in
effect for one year:
1) Directing Defendant to refrain from abusing the Plaintiff.
2) Prohibiting Defendant from having any contact with the Plaintiff, including, but
not limited to entering her place of employment, and from haraSSing the petitioner or petitioner's
relative~ or minor children.
3) Any such other relief as the Court deems appropriate and just.
. ,
~MAR 2 7 1998
SHAWNTA M.BAKER,
Plalnti ff
v.
IN TIlE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION-LAW
IN PROTECTION FROM ABUSE
KEn'H 1. BOYER,
Defendant
NO. 98- / )(Iu
CIVIL TERM
....go, of "'"" from Dof'"",,,. K"" ], Do,." 'h, fOllow,o. T'm_ Onl" b "'''''",
wlth,o Potlbe., "'d "P<>o """,.. '''', PI"ollff, S"Wo" M. """'" "'a, m moll.. "'d pre""
AND NOW, 'hi, ,,"'" ",y of M>reh , '998. "",. """'".", "'d ro,,,,,,,,,.,,, ofth,
.tEl\floR.o\RY PROTF.CTJYE ORDIm
her In fear of abuse, either personally or through his agents.
I. Def",,,,,,, ',onl,,,,, to """,0 from .h"io. " h'''''io. P'",o" ff, """"'"
Pennsylvania,
.. h" ""d",,,,. "'d It" ~.'" of 'm~oym"" " V",l,y M",,', ",'0" Hl.hw.y, "'"'ok,
2. Dof",,,,,,, " "d"", to 'my .w. Y from "'y I"""", whioh PI""i ff "'y ""blJ~
1unldns,
PI"", ff', "' -hU",,"d, Troy ] "ki ", ,l.", A,",y wjlJ be ',m""", I y ""d'.. wl" M"
"" ",.tI,"" ""'i""1I Y It" ,It lld"o, A'h I,y "toki" , M"'", S'"''', "'d .ri..... S'"''', ""
through third persons.
4, Dof"'...., ,,,~o,"'" from h'""".. "d ""'ki.. 'be P,",.. ff "'" from ........
P,,,.tlff l"".".., hut ." "m'"" to, '.'pho", "'d wri",o _mOOl"tlo"" "'d "'."',
" Dof""'"" " .nI,,,,, to ..f"" from h", '. ..y ",,,,, " "di"" ro."" wl 'h 'be
property,
S. Dof..d"" ".11 ref"" from .......'". " d'''''yl'. "'y .f PI""",., ..,,,'.,,
, ,
6. Defendant shall cooperate in selling a time when Plaintiff and a neutral party can
rctum to the fornler Joint residence at 51 Ballpark Drive, Gardners, PA 17324 without the
Defendant being present, ill order for Plaintiff to remove her personal possessions. Such time
wll/ be scheduled only through contact between Plaintifrs counsel and Defendant or Defendant's
counsel. Defendant may have a lIeutral third PlU1y present at the residence during this time.
7. Defendant shall temporarily relinquish to the sheriff all firearms in his possession
or control.
8. A violation of the Order may sUbJect the Defendant to: i) arrest under 23 Pa.C,S.
16113; Ii) a private criminal complalnt under 23 Pa.C.S. 16113.1; iii) a charge of indirect
criminal contempt under 23 Pa.C.S. 16114, 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, 16114,1.
9. Resumption of co-residence on the part of the Plaintiff and Defendant shall not
nullify the provisions of the court order.
10, A hearing shall be held in this matter on the J'" day of r,~J , 1998 at r.';:f~"
in Courtroom No. I ,Cumberland County COlJrthouse, Carlisle, Pennsylvania. Defendant is
hereby informed that he has the right to be represented by counsel. DEFENDANT IS
FURTHER INFORMED THAT ANY PROTECTION ORDER MAYBE CONSIDERED IN
ANY SUBSEQUENT DOMESTIC RELATIONS PROCEEDING, INCLUDING A CHILD-
CUSTODY PROCEEDING.
II. The Carlisle Police Department shall be provided with a certified copy of this
Order by the Plaintifrs 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