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Home My WebLink About01-2802 FX , , ~ , ~'~ I .'~'~ " " --1:. "d.- -, , -, -' '" - ""~ LAURETTE M. CASTAGNOLA, Plaintiff v. IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. (J h)-f(O.l. CIVIL TERM JOHNNIENlE E. WRIGHT, Defendant PROTECTION FROM ABUSE AND NOW, this TEMPORARY PROTECTION ORDER q ':ay of May 2001, upon presentation and consideration of the within Petition, and upon finding that the plaintiff, Laurette Castagnola, now residing at 122 Willow Mill Road, Mechanicsburg, Cumberland County, Pennsylvania is in immediate and present danger of abuse from the defendant, Johnnie E. Wright, the following Temporary Order is entered. *Law enforcement agencies, human service agencies and school districts shall not disclose the presence of the plaintiff in the jurisdiction or district or furnish any address, telephone number, or any other demographic information about the plaintiff except by further Order of Court. The defendant, Johnnie W. Wright, social security number 122-52-2139, date of birth May 14, 1958 and last known address 132 W. South Street, Carlisle, Cumberland County, Pennsylvania 17013, is hereby enjoined from physically abusing the plaintiff, Laurette Castagnola, or placing her in fear of abuse. The defendant is ordered to stay away from the plaintiffs residence located at 122 Willow Mill Road, Mechanicsburg, Cumberland County, Pennsylvania, a residence, which is owned/leased, solely by the plaintiff~ The defendant is ordered to refrain from having any direct or indirect contact with the plaintiff, the plaintiff s relatives, and the plaintiff s minor child including, but not limited to, telephone and written communications. ,~:'W!M".~"'i-ot,.L"'E"'''i}:,~",,,,,,'''cll~ ,~,"-l",;J,,~H~~(.Wi""_A;~~"'h~'~ ~-,,,.-",,' ,- ""-,< -,<. -- ",~,t.~H'" ",id, :}~ ,,'" ;;__;;,,~"johv1.S-;o~g~J::,l~-f'\(!I$k~'f/Jt,'1;W,I:OO<!'~~iI>!il'-'~!I~_~"!BJlili"~~"'i.'lI';,;jI~1\\I~_.&",;ii"" ~-i ii !j !I I i tl " E'1 &I-- l>?~ ~> k ~~. ~ ~ t) \f!Nb:li7IS )J.Nno,.-{ ,;~:, '~N3d ~ ~,.,.'..r,I)'{=JI':]f/~!n'" ~,': II,.) i U : 1/ !.11:1 - "> b- AViV 10 )"11'\1/(',[.;,, ,', -',~6f~;~~C:~'(~;j;:',~i - ~",U'"".~,:~~",l~ :"".~(LUJ ,r",:, ;"I~!L~";"2"","),~.,-,:,,,:,J-,.\,,,,,\v,,),,,,n ;";~,,,,~;_.,,,,~_;=,,.N~~'~' ~ .LL~~ ~_" ""-'" .. ~_\~.Y. '" '" ~~"'_ , "~"", ""'___"'~"~;:-__"!!'-"'""",,,""..,,l_~.'_,,,..' '"""",_" 'N"O ,~~,~ ~._ _"'_"'~''''~:~ 7" '" ". '" ,~-, . -~ l .--'- ~~fr The defendant is enjoined from harassing and stalking the plaintiff and from harassing the plaintiff's relatives an the plaintiff's minor child. The defendant is enjoined from entering the plaintiff's place of employment or the school(s) and daycare facility/facilities of the plaintiff's minor child. The defendant is enjoined from damaging or destroying any property owned jointly by the parties or owned solely by the plaintiff. A violation of this Order may subject the defendant to: i) arrest under 23 Pa.C.S. ~61l3j ii) a private criminal complaint under 23 Pa.C.S. ~61l3.1j iii) a charge of indirect criminal contempt under 23 Pa.C.S. ~61l4, 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. ~61l4.1. Resumption of co-residence on the part of the plaintiff and defendant shall not nullify the provisions of the court order. 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 fmds that the defendant has committed another act of abuse or has engaged in a pattern or practice that indicates continued risk of harm to the plaintiff. The defendant is ordered to relinquish to the sheriff's department any weaponls which he owns, possesses, has used or threatened to use against the plaintiff and the defendant is prohibited from acquiring or possessing any other weapons for the duration of this Order and is required to relinquish to the sheriff any firearm license the defendant may possess. The defendant's weapons and firearm license may be returned at the expiration of the Protection Order after the defendant has submitted a written request to the Court for the return of the weapons and the Court has notified the plaintiff of the request and given the plaintiff an ~~ . I I .,1 J, '"~ "'laiAl*~,' opportunity to respond. A copy of this Order shall be transmitted to the chief or head of the police department of Silver Spring Township and Carlisle, Pennsylvania and the sheriff of Cumberland County. A hearing shall be held on this matter on the I;; ~ay of , 2001, at ~m., in Courtroom No..3 , Cumberland County Courthouse, Carlisle, Pennsylvania. The plaintiff may proceed without pre-payment of fees pending further order of court. The Cumberland County Sheriffs Department shall attempt to make service at the plaintiffs 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 Sheriff for service. The Prothonotary shall not send a copy of this Order to the defendant by mail. The Pennsylvania State Police and the Police Department/s will be provided with a certified copies of this Order by the plaintiffs 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 of the police officer. In the event that an arrest is made 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 before the appropriate district justice. (23 Pa.C.S, 9 6113). By the Court, ~\ ., >_,J . ~;" v .'", <<i.;~~ --"t " - - -- -. '~t:< LAURETTE M. CASTAGNOLA, Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA : NO. CIVIL TERM JOHNNIE E. WRIGHT, Defendant : PROTECTION FROM ABUSE NOTICE 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 fail 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. Any Protection Order granted 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 a Protection Order, a surcharge of $25.00 will be assessed against you. You may also be required to pay up to $1,000.00 to reimburse Austin F. Grogan, Esquire for his representation of the plaintiff. You have the right to be represented by counsel. 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 TELEPHONE NUMBER: (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 must attend the scheduled conference or hearing. ',',-:."1;',,__,': '10__' . 'i< i-",':;"0"M-'~1~'..lli1<J1f1-f4Wbj,*~~%'i"'ri;,!<,,.,,,,...\1kk,,ij~*~'ii.>I&l!i~1I'i!r~B\Ii.~Ml~fuiI.,.;;;'Ili"!.i\i>lld::iWE>WllI!I_ :.iI<;o'''':,Bj'''~"~bk.j"IOi", "",aLPJ:W l-'~' <- 'A',:O'~d,!l,;.:'tiiib!.i-'J": ~k" ".,~--," '" -)"';<-"-, ~<,',<=," _~ ~e' "_~"~""'_"'" ""~~~ ___"""'~', \-f!t\\Vi':l!,q~N3d ,J;\'""\,,,v,. ,-'n"ln:J IL'ln'-{I (1\"'''') l\-'~C'V',1 /\ ':\ ,'", , \.,,, \.~ " .(1 I:" .() \'\"'l ;'; ~ ~ ,\:",4 ; n ..... '';.. , ~ , ,- !lJN.L<" i" ,~ ^ ^ M -~ ~, --~ ,. ^,~- --~ ,~"~-~~,, . . - '" ,~ '-' . , ~ l .....- ~' ,~ _',S ~"-":'~' LAURETTE M. CASTAGNOLA, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA v. : NO. 01- ;l So:z., CIVIL TERM : PROTECTION FROM ABUSE JOHNNIE E. WRIGHT, Defendant PETITION FOR PROTECTION RELIEF UNDER THE PROTECTION FROM ABUSE ACT, 23 Pa.C.S. S 6101 et seq. A. ABUSE 1. The plaintiff, Laurette Castagnola, is an adult individual residing at 122 Willow Mill Road, Mechanicsburg, Cumberland County, Pennsylvania. 2. The plaintiff is temporarily staying at an undisclosed location for her own protection and to avoid further abuse as is more fully set forth herein. This address will be furnished to the court upon request. 3. The defendant, Johnnie E. Wright, social security number 122-52-2139, date of birth May 14, 1958, and last known address 132 W. South Street, Carlisle, Cumberland County, Pennsylvania 17013. 4. The defendant has had an intimate relationship with the plaintiff. 5. Since December 2000 the defendant has attempted to cause and has intentionally, knowingly, or recklessly caused bodily injury/serious bodily harm to the plaintiff, committed rape, sexually assaulted or committed involuntary deviate sexual intercourse to her, false imprisonment pursuant to 18 Pa.C.S. S 2903, has placed the plaintiff in reasonable fear of ,,,,,I ,1~ '.l. " ~" "C '~-~illht-:;; imminent serious bodily injury, and has knowingly engaged in a course of conduct or repeatedly committed acts toward the plaintiff including following the plaintiff without proper authorization, under circumstances which have placed the plaintiff in reasonable fear of bodily injury. This has included, but is not limited to, the following specific instances of abuse: a. On Sunday, May 6, 2001 at approximately 8:14PM the defendant, Johnnie E. Wright, phoned the plaintiff at the plaintiffs residence and threatened to kill her and her "niger", most likely Merriel Conway. The threat of murder put the plaintiff in fear of serious bodily injury. b. On Friday, May 4, 2001 at 4:45PM the defendant, Johrmie E. Wright, left a voice mail message on the plaintiffs answering service indicating that he was going to "get her" and to call him when she got home. This threat placed the plaintiff in reasonable fear of serious bodily injury. c. On Thursday, May 3, 2001 the defendant, Johnnie E. Wright, continually contacted the plaintiff and repeatedly threatened the plaintiff with death and serious bodily injury. The plaintiff called the Silver Spring Township Police Department to request assistance and they advised the plaintiff that they could not do anything since the defendant allegedly called from Carlisle, Pennsylvania. The Plaintiff contacted the Carlisle Police ~, " L,. ~, " r'~ .i.'i: Department and reported the incident. The Plaintiff purchased a shotgun to protect herself. When the plaintiff advised the police that she had purchased a shotgun, for self-protection, the police advised the plaintiff to go home and use the shotgun if the defendant entered her house against her wishes. The plaintiff rejected the offer to go home and wait for the defendant to break into the plaintiffs home. The police further advised the plaintiff to get a hotel room to hide from the defendant. As the plaintiff was driving to a hotel for safety, the defendant jumped in front of her car, entered her car, and began assaulting the plaintiff and her male companion, Merrel Conway. Mr. Conway secured the shotgun and ordered the defendant to leave the scene and leave the parties alone. d. On Monday, April 23, 2001 the defendant, Johnnie E. Wright, appeared at the plaintiffs home while the plaintiff slept. The plaintiff was awakened by the defendant who began abusing her by choking her and straddling her on the couch and bed. The plaintiff eventually broke free from the defendant and called the police who arrived at the plaintiffs home in Silver Spring Township. Silver Spring Township police recommended that the plaintiff drive the defendant home to Carlisle, Pennsylvania. The '~L -~ . , ,-, ,-,-, ~","J.ci.,,",,-,-',l, defendant threatened to kill the plaintiff if she went to the police and reported any further abuse. Independent witness viewed the assault in Carlisle and called 911 to obtain police support to assist the plaintiff. The police, upon arrival, advised the defendant to leave the scene. e. On Sunday April 22, 2001, the defendant paged the plaintiff and demanded that the plaintiff go to the Carlisle area or he would come there. This put the plaintiff in fear of serious bodily injury. The plaintiff consented to avoid any further abuse. When the plaintiff arrived in Carlisle to meet with the defendant the defendant confronted the plaintiff and threatened the plaintiff. The police responded and advised the plaintiff to leave the area. No further action was taken by the Carlisle Police Department. f. In mid-April 2001, the defendant contacted the plaintiff and requested that she provide him gas money. The defendant threatened that if she would not bring the money he would come and "get her". The plaintiff met with the defendant to give him money for gas. As the plaintiff left the defendant's location in Carlisle, the defendant struck the plaintiff in the head and rendered her unconscious. The police were called and the plaintiff sought medical attention. The police indicated that they were planning to ~ " ,"," 1,'""_" ,~ ~~ file charges, however, they needed more time to prepare the charges. g. In mid-April 2001, the defendant rammed the plaintiff's vehicle and began stalking the plaintiff through Cumberland County ultimately resulting in police involvement in Silver Spring Township. The police detained the defendant and directed the plaintiff to go to the State Police and report the incident with the understanding that they would hold the defendant until the State Police responded. Trooper Long investigated the case. h. At the end of March 2001, the defendant tied the plaintiff up and threatened to kill the plaintiff if she did not consent to his orders. Subsequently the plaintiff talked the defendant out of killing her and releasing her from custody. Following the incident the plaintiff obtained a defiant trespass letter and served it on the defendant in front of the police in early April 2001. 1. From December 2000 until March 30,2001, the defendant routinely abused the plaintiff by choking, pinning down the plaintiff on various pieces of furniture, and threatened to kill her if she did not consent to his desires. 6. The plaintiff believes, and therefore avers, that she and her family are in imnlediate present danger of abuse by the defendant and that she needs such '" ~ _~. l. -',"~ ~~~~_ ~Ji protection from abuse. 7. The plaintiff desires that the defendant be prohibited from having any direct or indirect contact with the plaintiff and the plaintiffs family to include the plaintiffs father, Albert Castagnola, and Linda Castagnola, who reside at 18-20 East Main Street, New Kingston, Pennsylvania, and the plaintiffs minor child, Joselyne Trice, including, but not limited to, telephone and written communications. 8. The plaintiff desires that the defendant be enjoined from harassing and stalking the plaintiff, and from harassing the plaintiffs relatives. 9. The plaintiff desires that the defendant be restrained from entering her place of employment and/or schools and daycare facilities of the minor child. 10. The plaintiff desires that the defendant be enjoined from damaging or destroying any property by the plaintiff. 11. The plaintiff desires that any weapons the defendant owns, possesses, and has used or threatened to use against the plaintiff confiscated by the Sheriffs Department. B. EXCLUSIVE POSSESSION 12. The home, which the plaintiff is asking the Court to order the defendant to stay away from, is not owned or rented in the defendant's name. D. REIMBURSEMENT FOR COST OF CASE 13. The plaintiff asks that the defendant be ordered to reimburse the plaintiff for attorney's costs and fees in litigating this case. WHEREFORE, pursuant to the provisions of the "Protection from Abuse Act" of " " , , " .h,,'~ 'Hi~_':rj,. October 7, 1976,23 Pa.C.S. 9 6101 et seq., as amended, the plaintiff prays this Honorable Court to grant the following relief: A. Grant a Temporary Order pursuant to the "Protection from Abuse Act" 1. Ordering the defendant to refrain from abusing the plaintiff, her family, and/or the minor child and/or placing her/them in fear of abuse. 2. Ordering the defendant to refrain from having any direct or indirect contact with the plaintiff, her family, or the minor child including, but not limited to, telephone and written communications. 3. Ordering the defendant to refrain from harassing and stalking the plaintiff and from harassing the plaintiffs relatives and the minor child. 4. Prohibiting the defendant from entering the plaintiffs place of employment and the school(s) or the day care facility/facilities of the plaintiff's minor child. 5. Prohibiting the defendant from damaging or destroying property owned by the plaintiff. 6. Granting possession of the home located at 122 Willow Mill Road, Mechanicsburg, Cumberland County, Pennsylvania, to the plaintiff to the exclusion of the defendant. .-. ~~ I -'.-, ". l_. '- ~,- -" :.!a,-:G1i!iM:'!wi}, 7. Ordering the defendant to stay away from the plaintiffs residence located at 122 Willow Mill Road, Cumberland County, Pennsylvania, which the parties have shared, (and any other residence the plaintiff may establish.) 8. Ordering the defendant to relinquish to the sheriff s department any weaponls which he owns, possesses or has used or threatened to use against the plaintiff, her family, and/or the minor child, and prohibiting the defendant from acquiring or possessing any other weapons for the duration of the order. 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: 1. Ordering the defendant to refrain from abusing the plaintiff, her family, and/or the minor child and/or placing her/them in fear of abuse. 2. Ordering the defendant to refrain from having any direct or indirect contact with the plaintiff, her family, and/or the minor child including, but not limited to, telephone and written communications. 3. Ordering the defendant to refrain from harassing and stalking the plaintiff and from harassing the plaintiffs relatives and the plaintiff's minor child. . , ~, > , "-~--Il ':U 4. Prohibiting the defendant from entering the plaintiff's place of employment and/or the school(s) and/or the day care facility/facilities of the plaintiffs minor child. 5. Prohibiting the defendant from damaging and/or destroying property owned by the plaintiff. 6. Granting possession of the home located at 122 Willow Mill Road, Mechanicsburg, Cumberland County, Pennsylvania, to the plaintiff to the exclusion of the defendant. 7. Ordering the defendant to stay away from the plaintiff's residence located at 122 Willow Mill Road, Mechanicsburg, Cumberland County, Pennsylvania, which the parties have shared, (and any other residence the plaintiff may establish). 8. Ordering the defendant to relinquish to the sheriff's department any weapons which he owns, possesses or has used or threatened to use against the plaintiff, her family, and/or the minor child, and prohibiting the defendant from acquiring or possessing any other weapons for the duration of the Order. 9. Ordering the defendant to pay $1,000.00 0 reimburse plaintiff for the cost of litigating this case. The plaintiff further asks that this Petition be filed and served without payment of fees l_J, ~ "' ';', ~- :~ I -,- "c- and costs by the plaintiff, pending a further order at the hearing, and that a certified copy/certified copies of this Petition and Order be delivered to the Pennsylvania State Police/the Police Departmentls/appropriate police departmentls which haslhave jurisdiction to enforce this Order. The plaintiff prays for such other relief as may be just and proper. Respectfully submitted, Date ~A 10 I ~ Austin F. Grogan, s 24 North 32nd Street Camp Hill, Pennsylvania 17011 (717) 737-1956 Attorney for Plaintiff ID #59020 I~ ~,_ ^ ~ -' ~ ~,' _ , '-<';; >-' -J. ' ." - ,"~--",; -' '=, ~:t VERIFICATION I, LAURETTE CASTAGNOLA, certify that the statements made in the foregoing document are true and correct to the best of my knowledge, information, and belief and that this verification is subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Date s:19/0 I i~G LAURETTECAST~ ~"....,..'~~~' - ..J..,~ " : 1--1 ; ~" L j,~ ~-"",' 05/09/01 WED 1~:36 .F~ 717 240 6573 CUMB CO PRO~ONOTARY , @001 *************************** *u MULTI TN REPORT *u *************************** TX/RX NO INCOMPLETE TX/RX TRANSACTION OK 2600 01]9p2405331 04]92490779 CENTRAL PROCESS PSP ERROR , , OPPlCE Or TIfE PROTHONOTARY CUMBERl.AND CCUNI'Y muRTHOOSE ONE COOR1'HCXJSE SQUAAE CARl.ISf,E. PA. 17013-3387 (717) 240-6195 PAX (717) 240-6573 V I ATE LEe 0 PIE R '10: PA STATE POLICE. {Yr.,..,.I. PADiI!eu... ~. FAX "= 717-249-0779 F1lQof : CURTIS R. LONG RE: PFA ORDERS MESSAGE: .-L.ft ~ MJ. OF PAGES (INCr..uolNG (X)\,IER SHEET) 'Itris ~ is int:arlrl ally fur: tte tEe af l:tE irdiv:id.ID. cr rotit;y In <.hid! is is ~}l.; $1:,,::'. .nl lfBi a::rrtIDn inftmetim ttat is p:ivila;Jrl. anf:ida1t:ial 1rd ecEJTP: fu:m di....ln.llr~ ud!r >WH....nI.. I&r. If ttE ~ af ttUs ~ is rot tl-e intaml r:ocipient. }QJ are ~ rotifiB:1 ttat <n/ clli;saIrin'ItiOl. clistriI:J.itim cr a:wirg cf. this corm.nicat;01 .b strictly {XdtibitB:.\, If \0.1 h:M! m;ei.\oEd lJus a:mnnir.or..i(n in em:r. plea:;e rot:i.fY lG :imIH:lidtBly ~ teJ.ePl.:re 1rd teb.lm l.fe ocig:ire.lll -"'1" In 15 at ttE a-o,..: ~ v;iO tie ~!.S. JXEll2il 9i!l:vire. 'lta1< YUJ. , 1_ J ~ I, " ","",_,,-1"__ ,,~ , ' , 1"111~" .. . .' " LAURETTE M. CASTAGNOLA, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA v. : NO. 01-2802 CIVIL TERM JOHNNIE E. WRIGHT, Defendant : PROTECTION FROM ABUSE ~ ORDER AND NOW, this ~ day of May 2001, upon consideration of the parties Motion for Continuance it is hereby Ordered that a Hearing be scheduled for Wednesday, June 27, 2001 at 3 :OOPM, in Courtroom #3, Cumberland County Courthouse, Carlisle, Pennsylvania. By the Court, 1tu!.7'c';"l~kH;-,.ujfkwn~50"',;ldl~lfm_iiki_M;i~~f;H'iJ~d;jjll,Jlf',";",;Q.\j;c'iJ)_'",,;;o,,''';iW0,oi~.,i.IltII&JlWJW!Iilli!ffil@,,;il~A!l>1!.jj;;',ri;W~;l.W1__""~ia_~~'~~":'" ~ t {~' ~i, '.... i-~ , -- " ~ { L. "e" ~ _~ _ . .. - ,'~"~ ,,~,~.~ -~ w ... !""}"'-1lct\::: :~A \7il \' t; i \ 1'\",..1 \ -"~" )\_U'-\~r:!,'>;: ('1'- "I'--;'---'~"I',.rI~i\8 <';1 J ~l~ ~~, " , ~. ,,' ;\'" d , n ! t} ,- "" ,m.,i~,-'Wil"l -~f- '. " ..- ~ . - '"I "= . ~~. ~_".,,~~.J I , '"""l>,,,,,,,,,,"",,...,,,,<,U .. ,- ..- LAURETTE M. CASTAGNOLA, Plaintiff v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA : NO. 01-2802 CIVIL TERM JOHNNIE E. WRIGHT, Defendant : PROTECTION FROM ABUSE MOTION FOR CONTINUANCE AND NOW, this _ day of May 2001, upon agreement of the parties: 1. The Plaintiff requests a continuance in the above captioned case, which was scheduled for Wednesday, May 16,2001 at 4:00PM before the Honorable Judge George E. Hoffer, PJ; 2. The Defendant, Johnnie E. Wright, lUll'epresented at the Hearing requested a continuance in order to obtain his own legal counsel (copy of the Defendants written request is attached); WHEREFORE, the parties respectfully request this Honorable Court to continue the PF A Hearing to another date. Respectfully submitted, Austin F. Grogan, E uire 24 North 32nd Str t Camp Hill, Pennsylvania 1 (717) 737-1956 Attorney for Plaintiff ID #59020 Date 5{r'1(O( ",,' L~_.._<_, r-'~"" , , , '", ""~",~,~"~",,,,',,,,,"iI:Ui,,,j,,-",.&J,,>,;ti_~,,4i'-''''''~-'-'''-'';c''''_,''E';""'_'~ ' ~ "-'"",'<"1" [;-jfc-ol :J: 3Dt../rvuYlI B. [,U.;(,I6-v..fr R-(.=:~U<..--ST A CDP177/1(/Kh-i?dSm 7P D,{Z,7"X1-z,-,} ...Ar7. 4-TTOlUVey H>Lu 'T~f&cJ, .1 !i I I I I I I I I ! i I II " II II It 'I II II 11 II II II II ;1 .-1.1 it I ...............~ / L.-? -~~ ~..' . -" ~ ,,~ ,,, "" >1>BJli$0~' . " -. o o LAURETTE M. CASTAGNOLA, Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO. 01-2802 CIVIL TERM JOHNNIE E. WRIGHT, : PROTECTION FROM ABUSE Defendant l : 1'\ JrlER AND NOW, thiU day of ,2001, upon agreement of the parties and without a fmding of abuse and without admitting to the allegations in the Petition, the following Protective Order is entered: 1. Defendant, Johnnie E. Wright, is hereby prohibited from abusing, stalking, threatening, or harassing in any manner, including by telephone, the Plaintiff, Laurette M. Castagnola, either physically or by verbal threats, wherever she may be and is specifically excluded from the home located at 122 Willow Mill Road, Mechanicsburg, Pennsylvania, or any other residence she may establish. The Defendant is further prohibited from having contact or communication by any means with the Plaintiff. The Defendant is further restrained from entering the place of employment or business or school of the Plaintiff. 2. The Defendant is hereby notified that ifhe violates this Order, he may be held in indirect criminal contempt which is punishable by a fine not to exceed $1,000.00 and by a sentence of up to six (6) months injail and by other possible relief, or he may be held in civil contempt. Begiuning to or resumption of living at residence to which the Defendant is excluded by this Order could result in a fmding of indirect criminal contempt or civil contempt. Consent of the Plaintiff to resume contact or cohabitation does not invalidate, nullifY, or void the provisions of this Order as it relates to the prohibition against abuse. Further, any violation of this Order may also constitute a crime under the Pennsylvania Criminal Code, and those penalties may be in addition to those imposed as contempt pursuant to this Order. " . =~ ~. .k- ~, ~i;; . --- o o 3. Any police department having appropriate jurisdiction pursuant to the Protection From Abuse Act, 23 P.S. S6101 et seq., may arrest Defendant for violation of said Order without warrant upon probable cause whether or not the violation is committed in the presence of the police department. The Defendant's social security number is 122-52-2139. 4. This Order shall remain in effect for eighteen (18) months from the date thereof. S r. ...L~ v.l uus proceemng an;:: jJu,1.\."lvd '"'.1..1. tL._ 8_f_udu..L.LL ev~L~ UJ.v I.V bv !-,~d ....t tL._ n-r-h....~ nfFl!l.Dlutl~' ....-rrllmnp.rhmrl r....~,_~.1..:. BY THE COURT, J. ~r ~r.w;b";EI,~;rli:~,k,l%,&,,,,,,,,,,,,,",,,,,,-~,"-,,,;,~,,"'L~-,jO!,;,,"-';",'li'!./.M'!~j{t,"'-_")~.>>::hV"o"';,,:~,c,':',"-,,'~";io"'" ,,,;t. '''''''-'<';''l~' <I<,ti-l-:,~!l:'A;~~M\~'JlIil,1Jjl!i~_Elll!IlMI'___ ~~.L "'~"_'_~""__""9' _~. ~"~,~?_~~ ,,~ .~~''',"_'".' ~,,_.~,,_", '''''It. ~~ :-11 (\~ ,r-1:Jd \j\\\\:'i\ 1. \.)I.~:~ '!~:I _ '." , , I JYJ ,A..H\;nC~~ ,;,--:~" ,....' SS :E .,., l' ' .. ~>,", ,>,<, "'" '''"~'_'"" "",,"',~""'_""v,. ~. " i ~ : ;'~ 1,' ,-",~!" ,~.~ _""".''''='~''__'h. r .. , \ ".it ',e -""~.~"' , ~, 'J ;'.,'c- -"'~2'~i&i- ~. ..~ .J~ o o LAURETTE M. CASTAGNOLA, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 01-2802 CIVIL TERM JOHNNIE E. WRIGHT, Defendant : PROTECTION FROM ABUSE ~ S AND NOW, thig day of 2001, the parties agree to the following: 1. The Defendant, Johnnie E. Wright, will refrain from abusing, stalking, threatening, or harassing in any manner, including by telephone, the Plaintiff, Laurette M. Castagnola, either physically or by verbal threats, wherever she may be; 2. The Defendant specifically agrees to refrain from entering the residence located at 122 Willow Mill Road, Mechanicsburg, Pennsylvania, or any other residence the Plaintiff may establish. 3. Furthermore, the Defendant agrees to refrain from having contact or communication by any means with the Plaintiff. 4. The Defendant agrees to refrain from entering the place of employment or business or school of the Plaintiff. 5. The Defendant understand that if he violates this Stipulation, he may be held in indirect criminal contempt which is punishable by a fine not to exceed $1,000.00 and by a sentence of up to six (6) months in jail and by other possible relief, or he may be held in civil contempt. Beginning to or resumption of living at residence to which the Defendant is excluded by this Stipulation could result in a finding of indirect criminal contempt or civil contempt. Consent of the Plaintiff to resume contact or cohabitation does not invalidate, nullify, or void the provisions of this Stipulation as it relates to the prohibition against abuse. Further, any violation L -,~~ ~, , ' ~. ;-~,,. ='dn'......~- '~\, .', ~ . .- o o of this Stipulation may also constitute a crime under the Pennsylvania Criminal Code, and those penalties may be in addition to those imposed as contempt pursuant to this Stipulation. 6. Any police department having appropriate jurisdiction pursuant to the Protection From Abuse Act, 23 P.S. 96101 et seq., may arrest the Defendant for violation of said Order without warrant upon probable cause whether or not the violation is committed in the presence of the police department. The Defendant's social security number is 122-52-2139; 7. This Stipulation shall remain in effect until further Order of Court. 8. The Defendant, Johnnie E. Wright, enters this Stipulation without admitting any of the allegations set forth in the Protection From Abuse Petition. WHEREFORE, the parties respectfully request this Honorable Court to issue an Order ratifying this Stipulation. ~ 5~ ~~vJ 4111'ltlL\R J V - ,,1/01 - :~i~M;>:. ",l:I!!o1;~L1 :;"~ ,,:, h'<_,,,-;,;; "" _, -,,",,">:~'_c ,,'~.~-db.;'<'; '""~,L.,, ". ,..,:\,-, \,.' ,,'-,,_,: +, ,-C'i f" .~~J ~I!L,,'e-.".'." ,~.',,,,-_~:_i,_', .-.,,,_"L~i~;i~,,'i;,;,,=~""ill!1;.::;,,~,'m:lJ',Wj;';'.f.Mki,,;.,,,w,.i..""'iili!ir.k;!i-:1i!i:ii_,~I~'fill.,iW~~'Ji!~~ ~'~-'_'~'~ ,'~'" ~'~"".U,,"~. ,""" ""., _',""'",,,",,_ _"."",,<>_,,,,,_~,, _~".._"",,[. ",",_~ V!i\!\ ;\1" \~:;\i [,!::!d -" . .'-0- ,!,'.1'18 A.u\jnc~~ ' :[ , - ;:c;.<~, !p-; 82!1!ii ." d _' " '''"\ {;1J _~_, . .,,_.'~'c ~,' " ,'$":',,"'_'''', ",A_'" "'''', "",~',,..,,,,,_,,,,..,,r<, ,__~, ,,^,,,<a, ,~_~ "~,=__~ M"~ ." -. ,'. .. ~~<~~~"""~-~-~. -~-....""" ~ 'I I i 'I I '.~"",.L ~ ',"'~~;,,~~, SHERIFF'S RETURN - REGULAR CASE NO: 2001-02802 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CASTAGNOLA LAURETTE M VS WRIGHT JOHNNIENIE E DAVID MCKINNEY , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within PROTECTION FROM ABUSE was served upon WRIGHT JOHNNIENIE E the DEFENDANT , at 0017:25 HOURS, on the lOth day of May , 2001 at CARLISLE HOSPITAL 246 PARKER ST, ROOM 206 CARLISLE, PA 17013 by handing to JOHNNIE E. WRIGHT a true and attested copy of PROTECTION FROM ABUSE together with NOTICE OF HEARING & ORDER, TEMPORARY PROTECTION FROM ABUSE ORDER, PETITION and at the same time directing His attention to the contents thereof. Additional Comments DEFENDANT STATED THAT HE HAS NO WEAPONS Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 3.10 .00 10.00 .00 31.10 So l;pswers: /' ~~~,t!~ R. Thomas Kline 05/11/2001 Sworn and Subscribed to before By: JJ~J ffl'^!~~ Deputy Sheriff me this ~ 3~ day of ~ dkv ( A.D. ~Q, 7bwf~ ~' P othonotary ,