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Home My WebLink About98-06704 :-5 .. ~ I~ ; '" :.. ~ Q '" """ I\! 1[ i ~ , ... ~ IJ >- ' ~ 1:- ....j' I c.", . , ~i ~I I JILL ELAINE RICIIAKDSON. Plainti/r \", ClI\lIlFRI AND CO!INTY, I'EN"ISYI.VANIA '>0 fJ8- _i']~'-\L__ CIVIL TER\l ALEXANDER SI.OBOD:\:\ \IO:\IJCI I. DelcndillU . PROTECTION H{():\l AIlLSI, NOTICE OF HEARING AND ORDER YOV IIA VE BEEN SliED IN COVIU. If you wish 10 de/cnd against the claims set lurth in Ihe following papers. you must appear at the hcaring scheduled herein. If you tililto do so. the casc may procecd against you and a FINAL Ordcr may bc cntered against YOIl granting the reliefrequcsted in thc Petition. In particular. you may be evicted from )'our residence and lose other important rights A HEARING ON TillS MATTER IS SCHEDULED ON ..a_,....; ,1998, AT / /: 15 If .M., IN COURTROOM NO. / OF THE CUMBERLAND . COUNTY COURTHOlfSE, CARLISLE, PENNSYLVANIA, You MUST obcy thc Order that is attached until it is modilied or terminated by thc court after noticc and hearing, If you disobey this Order, Ihe policc may arrest you, Violation of this Ordcr may subject you to a charge of indirect criminal conlempl which is punishable by a tine of up to $1.000.00 and/or up to six months in jail undcr 23 Pa,CS, ~61 14. Violation may also subject YOIl to prosecution and criminal penaltics under the Pennsylvania Crimes Code. Under federal law, III US.c. ~2265. this Order is enforceable anywhere in the United Statcs. tribal lands. US, Territories and the Commonwealth of Puerto Rico, If yo 11 travcl outside of the statl' and intentionally violate this Order, you may bc subject to federal criminal proceedings undcr the Violcncc Against Women ACI, 18 USe. ~ 2261-2262, You should take this paper to your lawyer at once. You have the right to have a lawyer represent you at the hearing. The court will not, however, appoint a lawyer for you, If you do not have a lawyer or cannot afford one, go to or tclcphone the officc sct forth below to find Ollt where YOII can get legal help. If YOII cannot find a lawyer. YOII may have to proceed without one. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE, CARLISLE, PENNSYLVANIA 17013 TELEPHONE NUMBER: (717)249-3166 AMERICANS WITH DISABILITIES ACT OF 199Q The Court of Common Pleas of Cumberland Conllty is required by law to comply with Ihe Americans with Disabilities Act of J 990, For information about accessible facilities and reasonable accommodalions available to disabled individuals having business belore the court, please COnlact our ollicc, All arraogements must be made at least 72 hours prior 10 any hearing or business betore the court. You musl attend the scheduled conference or hearing, '; , ,! ~ ~ .~ v; ~ , ... .~ ~ }~ JILL ELAINE RICHARDSON. Plaintilf n IE COURT OF COMMON PLEAS OJ' ClI\lBERI.AND COUNTY. PENNSYI. VANI.' \'~ ;-';0 ()S-__&j(~:t_ CIVil. TERM ALEXANDER SLOBODA:-': \IO:\IICII. Dclcndant . PRO J"[ClION FRO\) ABUSE TEMPORARY PROTECTION FROM ABUSE ORDER Dcfcndant's Namc. ALEXANDER SL080DAi'\ MOi\llCH Defendant's Dale ofllirth. 10/06/74 Defendant's Social Security Number. 202-68-661:; Name of Protected I'erson: Plaintiff, JILL ELAINE RICHARDSON AND NOW,this II ~ay of NOVEMUER, upon consideration of the allllched Petition for Protection from Abuse. the court hereby enters the following Temporllry Order: lID I, Detendam shall not abuse. harass. stalk or threaten any of the above persons in any place where they might be tound. o 2, Defendant is evicted and excluded fromlhe residence at or any other permanent or temporary residence where Plaintiff may live, Plaintitl- is granted exclusive possession of the residence. Defcndant shall havc no right or privilcge to enter or bc prcscnt on the premises, lID 3, Defendant is prohibited from having ANY CO NT ACT with Plaintill. al any location, including, but not limited, to any contacl al Plaintitl's place of employment. DCfcndant is specilically ordered to stay away trom the following locations lor th~ duration of this Order: PlaintiWs residence located at 21 Village Court. Mechanicsburg, CumberJlInd Connty, Pennsylvania, and her place of employment. lID 4, Defendant shall not contact Plainlilrby telephonc or by any othcr mcans. including through third persons, o S I'el\(hnu the oUlwm\' or the tinal heannu III th" maller Plaintifr is awarded temflorar\' costod\' "rthe li,IIO\\ull! 1ll111l'r \'llIldlr"n (Inlil the linal hearin~, all contact hetween I>cfi:ndanl and 111l' child/rcn shall he limited 10 the Iilll"win~ The lucal law ent(lIcelllent agcncy in thc junsdicllon \\hcre the child/ren are I"cated shall cnsure that the childllcn arc placed in the care and control of Plainti!r in accordance with the Icrllls of this Order o 6. Defendant shall immediatcl\' relinquish the Iilllowing w~apons to the Sheriffs Ollice or 1\ designated local law enlixcclllcnt agency ftlr the delivery 10 the Sherifl's Ollice: Defendant is prohibited from pussessing. lransli:rring or acquiring any othcr weapons for the duratiun of this Order. 197 The following additional relicfis granted' The Cumberland County Sherit1's Departlllent shall allempt to make service at Plaintilr s rcquest and without pre-paymelll of Ices. but service may be accomfllished under any applicable Rule of Civil Procedure, This Order shall be docketed in the ollice of the Prothonotary and forwarded to the Sherin" for service. The Prothonotary shall not send a copy of this Order to Defendant by mail. This Ordcr shall rcmain in et1ect until modi lied or terminated by the Court and can be cxtended bcyond its original expiration datc if the Coun finds that De!endant has committed an act of abuse or has engaged in a pattern or practice that indicates risk ofharm to Plaintitf Delendant is enjoined from damaging or destroying any property owned solely by Plaintiff. Delendant is 10 rell'ain IrOln harassing Plaintilrs relatives, 19 8, A certilied copy of this Order shall be provided to the police department where Plaintill" residcs and any other agency specified hereatler. Hampden Township and East Pennsboro Township Police Departments. NOTICE TO DEFENDANT IIDq TIllS ORI>I'R Sf 'I'I:RSI'I>FS rID ANY PRIOR Ph\ ORDI,R and o ANY 1'1(1(11{ ORDFR RI:I.ATINCi TO ('1111.1> ('lISTOI>Y TillS ORDER APPLIES IMi\lEI)IATELY TO I)EFE!liI)A!liT A!liD SIIALL REMAIN IN HFECT li!liTIL :\IOIHFIEI) OR TER:\IINATEI) II\' TillS COIJRT AHER NOTICE AND IIE,\IUNG, Defcndant is hereby nOlilicd that violation of this Order may lesult in mTesl for indircct criminal contcmpt, which is punishablc by a line of up to $1,000,00 and/or up to six months in jail. 23 Pa,C.S, 96114, Conscnt of the Plaintitl' to Dcfcndant's rcturn to the rcsidcnce shall not invalidatc this Ordcr, which can only bc changcd or modilicd through thc tiling of appropriate court papers for that purpose. 23 Pa,C.S 96113. Dctcndant is further notified that violation of this Order may subject him/her to state charges and penalties under the Pennsylvania Crimes Code and to fcdcral chargcs and pcnaltics undcr thc Violcncc Against Women Act. f8 Us.e. 992261- 2262, Any protcction ordcr grantcd by a court may bc considcrcd in any subscqucnt procccdings, including child custody procccdings, undcr titlc 23 (Domcstic Rclations) of thc Pennsylvania Consolidated Statutcs, NOTICE TO LAW ENFORCEMENT OFFICIALS This Order shall bc cnforccd by thc police who have jurisdiction ovcr the plaintift's residence OR any locations where a violation of this ordcr occurs OR whcre the defendant may be located, If delcndant violates Paragraphs 1 through 6 of this Order. delcndant may be arrested on the charge of Indirect Criminal Contempt An arrest for violation of this Order may be made without warrant, based solely on probable causc, whether or not the violation is committed in the prcscnce of law cnforccmcnt. Subsequent to an arrcst, the law enforccment otlicer shall seizc all wcapons uscd or threatened to be used during the violation of this Order OR during prior incidents of abuse. Weapons must lorthwith be delivered to the Sheriffs otlice of the county which issued this Order, which otlice shall maintain possession of the weapons until lhrthcr Order of this Court, unless the JII.L I:I.AI:\I: RI('IIt\IW~():\, 1'lall1lltl' 1111. CO! 'It I or- C()~l\lm.. 1'1.I:t\S ()Jo ('I '\lIl1'RI'\"1> 011'" I y, 1.1.."....SyI.V,\'JI.\ \''\ '\:0 'IX. & le'l C1VIIITl{\1 ALEXANDER SI.OIlODA:\ \10\IICII. Dclclldant I'RO IU' 110:\ HW~I ,\IIIS... PETITION FOR PROTECTION FROM ABUSE Thr Plaintill'is JIll. 1'1 AINI' RICHARDSON, 2 Thc pcrson \\ho sceks pr,"cction from abusc IS 1'lailltitT. JILL ELAINE RICHARDSON, 3, Plaintil1's addrcss IS 21 Village Court, Mcchallicsburg, Cumberland County, Pcnnsylvania 17055, 4. Dcfcndant rcsidcs with his parrnts at 105 Glrn Road. Camp Hill. Cumbrrland County, Pcnnsylvania, Dcfcndan' is currcntly incarccratcd in Cumbcrland County Prison in Carlislc whcrc hc has bccn since hc was arrcstcd on Novcmbcr 18, 1998 Delcndant's Social Sccurily Numbcr is 202-68-6615, Delcndant's date ofhirth is 10/06/74, Dcfcndant is currcntly uncmploycd. 5, Defcndant has had an intimate rclationship with Plaintilf 6, Plaintill' and Defendant havc been involved in the following court action for support, or protcction from abuse: Case Name 10 Support 1998 l;;asC.J'JJL DR.272 I I pate Filed January 6, 1908 Court Cumbcrland Co,-Common Pleas 7, Detcndant has becn involved in the following criminal court action: Hampden Township Police Department tiled simple assault charges against Defendant stemming from the incident which occurcd on or about November 17, 1908, Defendant was arrested on November 18. 1998, arraigned, and sent to Cumberland County Prison where he remains on $50,000 bail. A prcliminary hcarin!( is schcdulcd hct.Jrc District Justice I'lacev on Wednesdav. Novembcr 25. IlJlJX, at '1,lOa m 8, The tilcts of the most recent incident of aouse arc as f.,lIows Apprmimatc Date, On or about "o\ember 17. I '!()S Approximatc lime, 200 am Placc 2 I Villalle Court, Mechanicsburg. Cumberland Coullly. Pcnnsylvania, l'laintitrs rcsidcncc On or ahout ~O\'cnlhcr 17. 199M, Dctendant poundcd on I'laintin"s bcdroom door and yclled to hcr that he had \Hillen all ()\'Cr hcr wall Whcn Plaintiff wcnt downstails. she foond that Dcli.'mbnt had wrillcn obsccnitics and sc,\ual CUlIlmcnts about hcr on thc wall with a markcr and thc partics argucd, Dcfendant punched Plaintitr in the jaw. slapped hcr lace sevcral times. bcgan writing on thc wall again. and shoved Plaintitl~ As Dclcndant Ictl I'laintitrs homc with somc of hcr posscssions. Dclimdant shovcd hcr away and punchcd hcr in thc lacc as shc crouchcd on thc floor. Whcn Plaintill'told Dcftmdant that shc nccded to go 10 thc hospital for trcatmcnt ofhcr injurics. hc told hcr that shc would bc okay and said shc could not go to work lalcr that morning because her co-workcrs would ask her how hcr injurics had occurcd, Plaimilr sought mcdical trcatmcm latcr in the day lor lacial injuries she sustaincd during this incidcnt. Plaintitr sustaincd injuries including bruising and swclling about hcr eycs. jaw. and nose. which was also brokcn. and continucs to havc hcadachcs as a rcsult of hcr injurics (sce attachcd Exhibit B. incorporatcd hcrcin by reference) PlaintitT reported thc incidcnt to the Hampden Township Police Dcpartment. who charged Defendant with simplc assault. Dcfcndant was arrested. arraigncd, and placcd in Cumbcrland County Prison wherc hc rcmains on $50,000 bail. A preliminary hearing is schcdulcd before District Justice Placcy on Wednesday, November 25, 1998, 9, Dcfendant has committcd the !ollowing prior acts of abuse against Plaintitl' a) On or about November 14, 1998. Defendant swung a bag of potatoes at PlaintitT hitting her on the side of thc f.1CC with it, grabbed her by the shoulders, shoved her to the floor, and struck hcr on thc back as she lay on the floor. Plaintiff sustained soreness and rcdncss about hcr lacc, and sorcncss about hcr back as a result of this incidcnt. b) In or about mid-Novcmber 1998, Dcfendant becamc angry and brokc Plaintifl's filII-length mirror and an heirloom dish belonging to hcr. Plaintiiffcarcd for her safety and Icft thc room, c) In llf ahuut carlv 'mcmher I'I'IX. Dctcndant called I'laintilr namcs and yclled uhscl'nilics at her. lerkl'd the cord IU hcr c1uck/radiu out of the wall, Ihrcw it on thc 110llf. stomped un it. and pulled hl'r jl'lwlrv hox apart and smashed it Fearing lilr hcr salcty. I'lailllil1'll'll the room d) In llf abuut :"llIemher 1'1'17. Dclcndantthrealencd I'laintilTtelling her that shc I\'ould be fuund III a ditdl I\' Ith her head cut 011'. I'laintilr lcared for her salcty, I'lailllilr ended her rclatiunshiJl with Delendant shurtly aileI' this incident and did not have rcgular cuntact with hint again until approximatclv mid-Scptcmbcr 199X c) In or ahnut Decemhcr 1')96. Plaintill: who was 2 months pregnant at the timc. was driving when Dcfendant grabbed the stecring wheel. causing thc car to vcer 011' the road. ami narnmly avoided causing an accident. Defendant grabbed PlaintitT by thc hair. repeatedly slammed her head against the driver's side window. took hcr wallet. and ran Ihlm the car. When Plainlilr returned home and told her roommate of thc incident. her roommatc callcd thc policc tor hclp. t) Since approximatcly I CJ96. Dcfcndant has abuscd Plaintill' in ways including. but not limitcd to. shoving. grabbing. slapping. punching, pulling her hair. spitting on her, throwing and/or breaking her personal possessions. writing on the walls of hcr residence. intimidating her if she relused to have scx with bim" and thrcatcning to kill her. 10. Thc lollowing policc dcpartmcnts or law enlorccment agencies in the area in which PlaintitT lives should be provided witb a copy of the Protection Order: Hampden Township and East Pcnnsboro Township Policc Dcpartments II , There is an immediate and present danger of further abuse from Defendant. 12, Plaintill' has sulrered the lollowing OUI-ol~pocket tinancial losses as a result of the abuse described above: see attached Exhibit A. incorporated herein by reference. WHEREFORE. PLAINTIFF REQUESTS THAT THE COURT ENTER A TEMPORARY ORDER. AND AFTER HEARING. A FINAL ORDER THAT WOULD DO THE FOLLOWING: A, Restrain Delendant Ii-om abusil;g, threatening. harassing. or stalking Plaintilf in any place wherc Plaintilrmay bc lound, B, Exclude Dcfendant from Plaintilfs residence and probibit Defendant from attcmpting to entcr any tcmporary or permanent rcsidcncc of the PlaintitT, (' Prohihit Ildi:ndant Ihlln havIII!! anv wnHlct Ilith I'lainllll: ellher in rlerson. hv Idl'phonl', or 111 I\lItlllfl 1ll''''"Hlllv or throuflh third pl'rson', 11I,1 lid III!(, hilt not li1l111ed ((I. any contact at Plaintill', place of elllplovment () Prohihillklcndant tiom haling any wntilct Ilith I'lainlil1\ relatile, E Direct Dclendant to PilY I'laintilr lor the reasonablc linanciallllsses sulrered as a rcsull of the abusc. tll be detellllined al the hearing F Order Dclendant to pay the COSIS or this action, includinfllilinfl and SCrvlCC Ices GOrder f)d<:lIdanl 10 reimhurse Cumberland Counly. a Legal Services tilllding source, $250.00 for the valuc of the leg,11 scrvices providcd to Plailllill'tor the cost of litigating this case ir the case goes to hearing, H, Ordcr thc tollowing additional rclict: not listcd above: Thc Dcfcndant is cnjoincd from damaging or destroying any property owned solely hy Plaintitr The Delcndant is to reti'ain from harassing Plaintilr s relatives, I. Grant such other relief as the court deems appropriatc, J Order the police or other law enforcement agency to serve Defendant with a copy of this Pctition. any Ordcr issucd. and the Ordcr for Hearing, The Petitioner will inform the dcsignated authority of any addresses. other than Dcfendant's residcncc, whcre Defcndant can be served, Respectfully submitted, Date: II -c?S- - f.f: 0. 7) . . ~<-- ({0cP-,=-L -1o;n Carey. Attorney for {ji~tiiT LEGAL SERVICES. INC. 8 Irvine Row Carlisle. PA 17013 (717) 243-9400 -, .. .,....,.'.,.,....'~,.,....~.". ~ :'.' ...., j=flo1b ~ &I UoI ~ Ol\ It b.~h tI'J~ -Su.c;~~ /.I/'Z/fig J.Ltl. -6. ~a!At"~~ . I ?f401O ~ bl{ LSI smFf' /l1~'S1i8 JAlJt.U"i~ 1>(A.6"1'J9/~ "/1"1/18 JIll 6. i:.ICfI~SbtJ ~,,"'r/::. .'-",'(71:'.,'--' '~"_;'~~:, I' f1-l6'lO ~~ "S..;, t'...J$> I e'~'l I J !&l:;~,,/q't IlJju~ ~NSO U't7/~ JIM o~I~~ EXHIBIT B JILl. I'I.AI:-';" I{I('IIAIWSOS, Plaintiff .HJ~__ -';'"'~.":';:,' .~ .. ',' .. '. .. "" '~C" , '.,"', ,_ ,,_ ,_:i.;l;\',,,,,,, -, ,_ '."'.. _.. .. ..,' "'._ _ .'- ,_ ,c'.f'.'" '''''''_'''''',' _'0 "," ',' .". '~.O' 1., ,. C ,'.. "._ . ... . .' .. '_.n,'_ '"O\."",,.,.~....... . _' . , . . ,_,_""'_' _0' ," ." ..,.....,., ,.".~,-'.,_".;., -.. ,< . _ .. .. -,.",.'01- .0" 1111, 1'1 II RI OF 1'( )\1\11 IS l'I.I't\S OF : ('( '\llll'IU,ASI> ('( II ':'I;IY, I'''SSSYI.V ANIA \'S. : '0, I)X.(,70-l ('I\'IIII'R\I Al.EXANDER SI.OIlOI>AN \010\11('11, Defcndant : I'IHHIT 110' FRO\I ,\Ill :S!' ASI> CUSTODY ORDER FOR-.-CONTt~lJANCE AND NOW, this 7'" day of.l>cccmhcr 1')I)X.upon considcration ofthc attachcd Motion lilr Continuancc, thc matter schcdulcd li.r hcaring on Dcccmhcr -I. I')')X. hy Ihis Court's Ordcr of Novemhcr 25.llJlJX, is hcrehy continucd gcncrally. This Ordcr is cntcred without prcjudicc to eithcr I'arty 10 rcquest a hcaring, The Tcmporary Protcction From Ahuse Ordcr shall remain in cftcctlilr a pcriod of one ycar Iromlhc dale it was cntcrcd or untilllll1hcr Order of Court, whichevcr comcs lirs\. Ccrtilicd copies of this Ordcr li,r Continuancc will he provided", li.e Pennsylvania Slate Policc and the Hampdcn and East Pcnnshorn Township Policc Departmcnts by thc plaintiff's attomcy. By thc Court. Joan Carcy LEGAL SERVICES, INC. Attorncy for Plaintiff /)/J// / 7w~~IJ;g~&- tl"~""~' q" .'"\-.....o..~Cq{ 1"'-/" I? f:. ,.s, "/,"'. Tcrcncc J, McGowan KILLIAN & GEPHART Attomcy Illr Dclcndant . ,. .... "','~'-'.: ',..\ , ,t,:" '. . .\ . ~.) i:.; :~ ;:.; II" .'i ',:, .......~ ~'... ;~j\_:.' . 'ih) __' ...... _<oJ _' , ,_ .. J __..,....'-' .......I..J JILL ""AIJ'\J: RICIIAIWSO:'\. "Iaintill :/111: ('(I( 'I{ I (1/: (,()\l\tlJJ'\ I'LE:\S OF : ('l :\tlll'l{l,A:'\D ('()\ -:'\ IY.I'E:'\J'\SYI.V,\NIA \'S, : :'>:0, lJS.(.711-1 1'1\'11. TER7-.t ALEXANDER SI.OIIODA:'>: MO\:ICII. Iklcndant : I'IWTlTT/O:'\ FRO\I AllliSE MOTION FOR CONTINUANCE Thc I'lailllill: Jill Elainc Richardson, hy and through her allomcy. Joan Carey of Lcgal Serviccs, Inc..movcs thc Court Ii.r an Order continuing gcncrally Ihe hearing in thc ahove-eaptioned casc on thc grounds Ihat: I, A Temporary Protection From Abuse Ordcr was issued hy this Court on . Novcmhcr 25. 1998. scheduling :1 hcaring Iilr, December -I, 11)98. al II: 15 a,m. 2, The Cumherland County Sheri n's Department servcd Dclcndant wilh a eertificd copy of thc Temporary Protection From Abuse Order and Pelition Iilr Protcction From Abuse on Novcmbcr 30, 19'18. 3. The Dclcndant has retaincd Terrcnce J. McGowan to rcprcsent him in thc mallcr. 4. Thc partics agrcc, by and through their rcspcctivc counsel, that thc hcaring hc continucd gcnerally to an,ml thcm timc to exccutc a conscnt agrecmcnt. 5. The PlaintifTrcqucsts that thc Tcmporary Protcction From Abusc Ordcr rcmain in cffect lor a period ofonc ycar Ii-om thc datc it was cntered or until furthcr Ordcr of Court, whichcvcr comcs first. WHEREFORE, the Plaintiff requcsts that thc Court grant this Motion and continuc this mattcr gcncrally. and thatthc Tcmporary Protcction From Abusc Order rcmain in cffcct for a pcriod of onc ycar frclln thc datc it was cntered or until furthcr Ordcr of Court. whichcvcr comcs first. Rcspcctfully submitted, , ([) IS """'L-,'U ~'t^_, ()''''~1 Carey. Attorncy fo LEGAL SERVICES, INC. 8 Irvinc Row Carlislc. PA 17013 (717) 243-9400