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LAW 0""101:;5
SNELBAKEIl.
BRENNEMAN
Be SPARE
reoklessly oausing bodily injury to Petitioner in the following
manner:
Respondent did forcibly enter Petitioner's
residence after being repeatedly requested to leave the
premises. While Petitioner was entering the front door
of the premises, Respondent did foroibly pull open the
door to gain entry to the premises thereby causing
injury to Pet! tioner' s wrist oausing her to seElk and
obtain medical treatment and to be required to miss
work for a pedod of three days.
Respondent repeatedly threatened bodily injury to
Petitioner and Petitioner's brother who was present
with Petitioner at the time of the incident set forth
above.
5. Respondent's actions as set forth above caused
Peti tioner substantial pain and injury.
6. On other occasions, Respondent has verbally harassed
Petitioner and physioally threatened and abused her as follows:
a. In June, 1997, Respondent in a fit of anger,
pinned and restrained Petitioner to a couch causing
bruises to Petitioner's collar bone and throati
b. In October, 1997, Respondent carne after
Petitioner when Petitioner was in a motor vehiole and,
when unable to physically grab Petitioner, struck the
hood of Petitioner's vehiole oausing damage to the
vehiclei
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LAW Ol'FICE;O
SNELBAKER.
BRENNEMAN
Be SPA,.E
c. In Ootober, 1996, in a fit of anger and rage,
Respondent did foroibly physically throw Petitioner
onto a couch i
d. Respondent on several ocoasions in anger threw
items toward and around Respondenti and
e. Respondent threatened injury to Petitioner.
7. Petitioner believes and therefore avers that she is in
immediate and present danger of abuse from the Respondent and
that Petitioner is in need of protection from such abuse.
8. The Petitioner desires that the Respondent be ordered to
refrain from having any contaot with Petitioner including, but
not limited to, entering the property and residence at 4 North
stoner Avenue, Shiremanstown, which previous to the initiation of
the divorce prooeeding was the parties' marital residence, and
entering Petitioner's place of employment and harassing the
PetJ.tioner.
COSTS AND ATTORNEYS' FEES
9. The Peti ti.oner asks that the Respondent be ordered to
pay the costs of fiUng and service of this Petition and to pay
reasonable attorneys' fees pursuant to the Protection From Abuse
Act.
WHEREFORE, Petitioner requests this Court to grant the
following relief;
A.
Grant a Temporary Order:
1. Requiring the Respondent to refrain from
abusing the Petitioner or placing the
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