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Owen E, Olasser,
Plaintiff
[N THE COURT OF COMMON PU:AS N'
v,
CUMBERLAND COUNTY, PENNSYLVANIA
David A, Wire,
NO, 98-
CIVIL TERM
Defendant
PROTECT I ON FROM ABUSE
NOTICE
You have been !luud in court, I f YOU wi sh to (Jpf"nd 1l1~lIi n,st thf1
claims set forth in the following pages, YOll must take action promptlv
aft.er this Petition, Order ami Notice IIl'fI Sf'I'YlHl. hv 1I0llfllll'inu
personally or by att.orney at the hearing scheduled by the Court and
presenting to the Court your defenses or ohlcctlons to the claims sot
forth against you, You aro wlHned that if you fai I to do so the Court
may proceed without you, Ilnd a .iudgment mav be entered against vou bv
the Court without further notice for any monuy claimed in the Petition
or for any other claim or relief requested by the Illltlntiff, Vnu mav
lose money 01' property or other rights important to you. Any
Protection Order grnnted by a Court may be considered In any
subsequent domestic relations proceedings, including custody actIons.
FEES AND COSTS
If the case goes to hearing and the Judge grants II Protection
Order, ft surcharge of $25.00 wil I be assessed allainst vou, You mav
also be required to pay up to $250,00 to reimburse one of LbRal
Services, Inc, 's funding sources for LCRal 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, I f 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 Ret leRal help.
CUMBERLAND COUNTY BAR ASSOCIATION
2 L [BERTY A VENUE
CARLISLE, PENNSYLVANIA 17013
TELEPHONE NUMBER: (717) 249-3166 01' 1'01.1. FREE: l-ROO-990-9101l
FAX: (717)249-2663
~ERI~ANS WITH DISA8ILI1'IES 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
avai lable to disabled indlvidu/lls havlnl( business before the court.
please contact our office. All afl'llngements must be made at least 72
hours prior to any hearing or business before the court. You must
attend the scheduled conference 01' hearing,
occasions, threntened to "fuck her up" causing her to
feur for her safety,
b. In or about Jnnullry 1998, the defendant becume
angry and punched the plnintlff in the chest causing a
bruise.
c.ln or IIbout December 1997, the defendant punched
the pllllntlrf several times about her head and bOdy
clIuslng her to fall nnd hit her hend on the corner of
an end table and temporarily lose consciousness. The
defendant pushed the pialntlff, slapped her across the
face, and threw her onto the furniture. The Incident
resulted in swellIng on the plalntiff'R hend and
bruising and soreneSR In her neck, shoulders, and
torso.
d. In 01' nbout November tCjlj7, the defendant pushed
the plaintiff, choked her, picked her up and threw her
onto the floor, love seat, and Rofa,
e. On several oceaRions since November 1997, the
defendant has abused the plnintiff In ways Including,
but not Ilmi ted to, the following: pUshing /lnd shoving
her, choking and punching her, tripping her causing her
to filii, slapping her on the legs, and grabbing her
legs causing pain and bruises,
5. The plaintiff believes and therefore avers that she is
in Immediate and present danger of abuse fromihe defendant and
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that she Is In need of protectIon from such abuse.
6. The pllllntlff desln's Ihllt the defend/lnt be prohibited
from having any dlrecl or indirocl contact with the plaintiff
Including, but not I lmi ted to, ((dephonlJ und wri t ten
cornmunlcnt Ions.
7. The plninlif" desires that the defendant be enjoined
from harnsslng nnd stalking the plaintiff, and from harassing the
plnintlff's relatives.
8. The plaintiff desires that the defendant be enjoined
from damnglng or destroying any property owned solely by the
plaintiff.
lh. EXCL.U.s.1XE-l'.QSsr~s~ IO~
9, The mobite home which tho plaintiff is asking the Coutt
to order the defendant to slay aWny from Is not owned or rented
In the defendant's name.
to. The defendant has his own residence the location of
which Is unknown by the plulntiff,
~__~E I M8lJRI!.EMENT ....!':QIL.Q9Jl....T.....QE.!i..M.l\
11. The plaintiff asks that the defendant bo ordered to pay
$250.00 to relmburst. one of LtJglIl ~ervjc()s, Inc.'s funding
sources for the cost of Ii tigat ing this cuso.
WHEREFORE, pursuant. to t.htJ provisions of tho "Prott:lctlon
from Abuse Act" of October 7, 1'176,7.3 I'II.C.S. 96101 III ~q., as
.1
amended, the plalntHf pruys this lIonoruble Court to grant the
following ra lief:
A. Orant a Temporary Order pursuant to the
"Protection from Abuse Aut:"
1. Ordering the defendant to refrain from
ubusing the plulntiff or from placing her in feuI'
of abuse.
2, Ordering the defendant to refrain from having
any direct or Indirect contRct with the plaintiff
including, but not I iml ted to, telephone und
written co"~unicatlons.
], Ordering the dufendant to refrain from
harassing and stalking the plaintiff and from
harassing the plaintiff's relatives.
4, Prohibiting the defendant from damaging or
destroying property owned solely by the plaintiff.
S. Ordering the defendant to stay away from the
plaintiff's residence located at 40 Rolo Court,
Mechanicsburg, cumberland County, Pennsylvania,
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 a period of one year:
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I. Ordering the defendant to refrain from
abusing the plaintiff ~r 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 ptalntlff and from
harassing the plaintiff's relatives.
4. Prohibiting the defendant from damaging or
destroying property owned solcly by the plaintiff.
S. Ordering the defendant to stay away from the
plaintiff's residence located at 40 Rola Court,
Mechanicsburg, Cumberland County, Pennsylvania,
and Bny other residence the plaintiff may
establ Ish.
6. Ordering the defendant to pay $250.00 to
reimburse one of Legat 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 a certified copy
of this Order be delivered to the Upper Allen Township Police
Department which has jurisdiction to enforce this Order.
5
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