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Home My WebLink About98-03249 8. The defendant is ordered 10 address his anger nnd violent behavior by enrolling in the ballerer treatment program (,H()f('J\~", through Tressler Lutheran Services, 960 Century Drive, Mechanicsburg, PA 17055, Telephone: (717) 795-0330, within ten (10) dnys of the entry of this Order. If the defendant is incarcerated at the time thl: Order is entered, he shall enroll in the program within live (5) days of his release from prison, The defendant shall remain in the program until he has successfully completed all counseling and administrative requirements and is released by the program facilitator. The defendant shall pay nil costs related to the CH()f('J\S program prior to his release from the program, 9, This Order shall remain in elreet for a period of one ( I) year and can be extended beyond that time if the Court tinds that the defendant has committed an act of abuse or has engaged in a pattern or practice that indicates risk of harm to the plaintiff This Order shall be enforceable in the same manner as the Court's prior Temporary Protection Order entered in this case, ] 0, A violation of this Order may subject the defendant to: i) alTest under 23 Pa,C.S, ~611J; ii) a private criminal complaint under 2J Pa,C.S, ~611J I; iii) a charge of indirect criminal contempt under 23 Pa,C.S, *61] 4, punishable by imprisonment up to six months and a tine of $100,00-$1,00000; and iv) civil contempt under 23 PaC.S. *6114, L I ] , The Silver Spring Township Police Department shall be provided with a certified copy 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 Ordllr has been violated, whether or not the violation is committed in the presence of the police officeI'. In the event that an arrest is madr. 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 County, Pennsylvania, and any residence the Plaintiff may in the future establish for herself. 7. The Defendant agrees to address his anger and violent behavior by enrolling in the batterer treatment program CHOICES, through Tressler Lutheran Services, 960 Century Drive, Mechanicsburg, PA 17055, telephone (717) 795-0330, within ten (10) days of the entry of the Protection Order. If the Defendant is incarcerated at the t.ime the Order is entered, he agrees to enroll ill the program within five (5) days of his release from prison. The Defendant agrees to remain in the program until he has successfully completed all counseling and administrative requirements and is released by the program facilitator. The Defendant agrees to pay all costs related to the CHOICES program prior to his release from the program. S. The Defendant, although entering into this Agreement, does not admit the allegations made in the Petition. 9. The Defendant understands that the Protection Order entered in this matter will be in effect for a period of one (1) year and can be extended beyond that time if the Court finds that the Defendant has committed an act of abuse or has engaged in a pattern or practice that indicates 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. 2 {;: ,0;-,' /0-:-; ~6' 'R~l if $,11/'" y}L' ~(') li,:ul ~ ~; t5 "'/ ". (1ft: Q ~ ) '~ .... j <.. ~ I.'i .... , '" , ,;:'~' '. ,:1''' c...: fro: , i -:', ',I.) !,,_.' I_;u!..f "-,i" ':-_,~ .1.. ~j Q .;'k..J J ?R ji CEflTIFIC^TION OF PF^ CONTEMPT Case NumberqC;:_,32.,I:L9_ Name Pa.lriclC1!1.~o.e.L~1.Jh.\la.n_~ ~~~~:'Pli~Jo:0 Balance Due: $.9-9.:.JCl.__ 170 State Surcharge 1'/1 State Fine 260 Sheriff Cost ($1.50 + any addtl) 207 District Attorney 204 Court Costs (Clerk of Court) 502 fleslitlltion Name .ff-dhono\o.r_Y.5_()tFic~__ s Address . --_.._-~.. -"~~---~._---, -_.___.~, __ ~___, '_'h ~____..__ _.______ City State ..-------...------ Name $ Address ,City State N.\Ime Address City State Victim's Name: AmuukAllCol e Ce~~ H5.iQ $ Zip __.____.:...._. $ ~ Zip zip ::::::"::::: ,::::":" foom, <to"~:L ~ ,."" 9- N! 'I, ~, . ,~' i;'.:'~ I , ., .~ -9" " , " ., '\ /1l' " ','~ I ,~~(~ ,'i~ iitt ." '\"J.t "f: ,...~i.'4.~.'." (I' , j:, ".' , {!~. i' ..\",~. '\t ~ , " " . .. ."ll' ,\r' , .i~~;~i..~,~;1~ ....! ;.. ," \ t ':'\. ." '; ~ ' ~~o " ""Ill!:' \ I .. ~ ~, ( { .i ";: !1l l~. .., , . .' " , AMANDA NICOLE GEITZ, Plaintiff IN TIlE COURT OF COMMON ('LEAS OF v. CUMBERLAND COUNTY, I)ENNSYLVANIA NO,98-_';<.)Yl'n_ CIVIL TERM PROTECTION FROM ABUSE PATRICK MICHAEL SULLIVAN, Defendant TEMPORARY PROTECTION ORDER AND NOW, this ft!) day of June, 1998, upon presentation and consideration of the within Petition, and upon finding that the plaintiff, Amanda Nicole Getz, now residing at 145 Woods Drive, Mechanicsburg, Cumberland County, Pennsylvania, is in immediate and present danger of abusc from the defendant, Patrick Michael Sullivan, the following Temporary Order is entered, The defendant, Patrick Michael Sullivan (SSN: 166-58-9236)(DOB: 03/27177), currently incarcerated in Cumberland County Prison, Carlisle, Pennsylvania, is hereby enjoined from physically abusing the plaintiff, Amanda Nicole Getz, or from placing her in fear of abuse. The defendant's permanent address is the residence of his parents, Joseph and Gail Sullivan, 3612 Kent Drive, Mechanicsburg, Cumberland County, Pennsylvania, The defendant is ordered to slay away from the plaintiffs residence located at 145 Woods Drive, Mechanicsburg, Cumberland County, Pennsylvania, a residence which is owned by the plaintiffs mother, and is ordered to stay away from any residence the plaintiff may in the future establish for herself. The defendant is ordered to rerrain from having any direct or indirect contact with the plaintiff including, but not limited to, telephone, written, or third party communications. The defendant is enjoined from harassing and stalking the plaintiff or her relatives, The defendant is enjoined from going to the plaintiff's place of employment. I Thc dcfcndant is cluoincd from damaging or destroying any propcrty owncd by thc plaintiff. A violation or this Order may subject the derendant 10: i) arrest under 23 Pa.C.S. 16113; Ii) a private criminal complaint nnder 23 Pa.eS. 116113.1; ill) a cha!'Re or indirect criminal contempt under 23 Pa.e.s. 116114. punishable by imprisoument up to Iii month. and a fine orsIOO.OO-$I.OOO.oO; and iv) civil contempt under 23 PlI.C.S.li6114.1. Resumption of co-residem~c on the part of the plaint ill' and defendant shall not nullity Ihe provisions of the court ordcr, 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 an act of abuse or has engaged in a pattern or practice that indicates risk of harm to the plaintiff. A HEARING SHAtL BE HELD ON THIS MATTER ON JUNE iL. 1998, A l' / /.. 00 LL.M.. IN COURTROOM NO. 2... OF THE CUMBERLAND COUNTY COURTHOUSE, CARLISLE, PENNSYL VANIA. The plaintiff may proceed without pre-payment of fees pending a further order after the hearing. The Cumberland County Sheriffs 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 Sherif}' tor service, The Prothonotary shall not send a copy of this Order to the defendant by mail, The Hampden Township Police Department shall be provided with a certified copy 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 the hall'., slammed hel head down on the table, pushed her face against the table, Jerked her lip Irom the table by the hair, shoved hl\r backward against the table, and up-ended the table on her. The Hampden Township Police were called, The dellll1dant was arrested and charged with simple assault, Uail was set at $25,000, and he was remanded to Cumberland County Prison, Al th<l preliminary hearing held before Distl-ict Justice fllacey on May 27, 1998, the defendant pled guilty, and is being held in prison on detainers for violation of his probation, The plaintilf sustained sorene~s aboul her head and I(lrehead as a result of this incident. b) In or about early May 1998, the defendant telephoned the plaintil1; demanded lhat she go out with him, and when she refused to have any further involvement wilh him, he told her that he had bought a gun, This incident occured close in time to an incident in which the defendant attempted to kill himself by ingesting a quantity of his grandmother's medication, and said that he wished that he was as strong as his mother, who had taken her life when the defendant was a child, The plaintiff' feared for her safety because of the defendant's instability, c) In or about March 1998, the defendant jerked on the emergency brake while the plaintiff' was driving causing the vehicle to swerve, The plaintif, who also had the parties' 4-month-old baby in the car, feared for her safety and thllt of the baby, d) In or about September 1997, the defendant threw a chair to the floor breaking it in halt; pushed over a reclining chair, and shoved the plaintift; who WllS 7-months pregtlant, causing hel to fall backward over the recliner, The plaintiff' reported the incident to the police, the defendant. was charged with disorderly conduct and harassment, and he was fined, e) In or about May 1997, the defendant Ibllowed the plaintitrs vehicle, driving close her vehicle's rear bumper. When she parked her car and got out, be walked up to her, spat in her face several times, grabbed her by the hair, spat on her again, jel'ked her head toward him, shoved her away from him, and used his keys to scrape paint olT the side of her newly purchased vehicle, When the plaintiff, who was 3-rnonths pregnant, walked away, the defendant swerved his vehicle toward her \:ausing her to move aside 'to avoid being stlllck, I) In or about summer 1996, the defendant broke into the plaintitrs residence while she and her family were away, telephoned hel pager Irom her residence, and when she returned home she found the defendant IlImmaging through her belongings, The defendant took leHers and other possessions belonging to her outside and burned them on the grill, gl In or about winter 1996, the defendllnt threw a pool chalk cube at the plaintiff hitting her under the eye, threw a glass ashtray at her hitting her in the forehead, slapped her in the face, jumped up from his seat, and rushed at her throwing his body against hers, causing her to slam against the wall. Two bystanders had to pull the defendant off of the plaintiff to keep him from further abusing her, When the plaintiff left and went out to get into her car, she found that two of the tires had been flattened, both side mirrors had been broken off of the car, and both headlights had been bashed in, The plaintiff sustained a laceration on her scalp and under her eye, and swelling and soreness about her head as a result of this incident. During another incident which occured in or about winter 1996, the defendant struck the plaintiff twice in the head and once in the face with a vodka bottle as she was driving, The plaintiff sustained a lacerated lip and ('lie of her front teeth was chipped as a result of this incident. The plaintiff sought dental attention for her injury and was titted with a crown over her damag~>d tooth, h) In or about September 1995, the defendant, who was attending high ~hool with the plaintm~ aeeosled her in science class stabbing a pencil point into her leg several times, repeatedly pinched her about her arm, causing bruising and swelling, and using his leeth, pulled a clump of hair Irom her head. When the plaintiO' walked out of the classroom, the defendanl slammed her againsl a wall and restrained her in a choke hold as sh.. tried to leave school. The police were called, the delendant was arrested, expelled from school, remanded to juvenile authorities, and sent to George Junior Detention Center in Grove City, PA, for 6 months, i) In or about August 1995, the defendant grabbed the plaintiff by the front of her clothing, jerked her up oil' of the couch, shoved her back down onto the couch. struck her on the shoulder repeatedly using the heel of his hand causing her to stumble backward, knocked her to the floor, straddled her, and choked her with both his hands while repeatedly slamming her head against the 0001'. j) Since approximately 1995, the defendant has abused the plaintiff In ways ! including, but not limited to, shoving, punching, slapping, pinching, atld reslraining her; pulling her hair; spitting on her; throwing objects at her such as an ashtray and pool cue chalks; striking her with objects such as a vodka bottle.; threatening to kill her and himself; and threatening 10 take her "down" with him. The defendant has also told the plaintiff that he hates their inllmt daughter and has threatened to abscond with the baby. The defendant has broken furniture, punched holes in walls, and caused significant damage to her vehicle by vandalizing it. The defendant has also telephoned the plaintiff's home repeatedly at all hours, and has yelled and screamed obscenities at both the plaintiff and her mother when they have told him not to call again, On one occasilln recently, the defendant telephoned the plaintill's home approximately 50 times within 24 hours. k) In addition, the defendant's instability has Increased recently, as evidenced by his attempt to take his life by ingesting a quantity of medication, alluding to suicide saying that he wished that he had the strength that his mother did to be able to follow thmugh with the act, telling the plaintiff that he had bought a gun after threatening to kill himself, lacerating his wrist in her presence, and ptllling off the road and threatening to kill himself by jumping in front of a tractor trailer. The defendant has also displayed other disturbing self-destructive behaviors indicative of his instability by slamming his head against floors and walls, punching himself in the face, and driving while intoxicated, 6, The plaintiff believes and therefore avers that she is in immediate and present danger of abuse from the defendant and that she is in need of protection from such abuse, 7. The plaintiff desires that the defendant be prohibited from having any direct or indirect contact with the plaintiff including, but not limited to, telephone, written or third party communications. 8, The plaintiff desires that the defendant be enjoined from harassing and stalking the plaintiff or her relatives, 9, The plaintiff desires that the defendant be restrained from going to her place of employment or the day care facility of the minOl' child, lO, The plaintiff desires that the defendant be enjoined from damaging or destroying any property owned by the plaintiff p. EXCUJSIV"-; POSSESSION I I, The home local,~d at 145 Wood~ Drive, Mechanicsburg, Cumberland County, Pennsylvania, from which the plaintiff' is asking the Court to order the delendant to stay away, is owned in the name of the plaintiff's mother. Sherry Getz, c. R~:IMBURSEM~:NT FOR COST OF CASE 12, The plaintiff asks that the defendant be ordered to pay $250,00 to Cumberland County, one of' Legal Services, Inc.'s funding 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 hearing, WHEREFORE, pursuant to the provisions of the "Protection from Abuse Act" of October 7, 1976,23 P,S, *6101 ltl. ~" as amended, the plaintiff prays this lIonorable Court to grant the following relief: A. Grant a Temporary Order pursuant to the "Protection from Abuse Ad:' I, 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, written or third party communications, 3, Ordering the defendant to refrain from harassing and stalking the plaintifl' or her relatives, 4, Prohibiting the defendant from going to the plaintiffs place of employment or the day care facility of the minor child. 5, "rohibiting the defendant from damaging {)I' destroying any property owned by the plaintitl', 6, Ordering the defendanl 10 stay away from the plaintitl's residence located at 145 Woods Drive, Mechanicsburg, Cumberland County, Pennsylvania, and any residence the 1,laintil1' may in the tUlure establish for herself B. Schedule a hearing in accordlmce with the provisions of the "Protectioll from Abuse Act," and. after such heal'illg. ellter all order to be in effect for a period of one year: I, Ordering the defendant to rell'ain 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, written or third party communications, 3, Ordering the defendant to refrain from harassing and stalking the plaintiff or her relativJs, 4, Prohibiting the defendant from going to the plaintiffs place of employment or the day care facility ofthe minor child, 5. Prohibiting the defendant from damaging or destroying property owned by the plaintiff, 6, Ordering the defendant to stay away from the plaintiffs residence located at ]45 Woods Drive, Mechanicsburg, Cumberland County, Pennsylvania, and any residence the plaintiff may in the future establish for herself,