HomeMy WebLinkAbout99-05282
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Plaintiff
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DANIEL G. JOHNSON,
Defendant
:IN THE COURT OF COMMON PLEAS
:OF CUMBERLAND COUNTY, PENNSYLVANIA
:NO. 99 - Sa Ci? CIVIL TERM
:PROTECTION FROM ABUSE
NOTICE OF HEARING AND ORDER
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims
set forth in the following papers, you must appear at the hearing scheduled
herein. if you fail to do so, the case may proceed against you and a FINAL
Order may be entered against you granting the relief requested in the
Petition. In particular, you may be evicted from your residence and lose
other important rights.
S? A hearing on this matter is scheduled for the L_ day o£
1999, at IB .m., in Courtroom No. of the
Cumberland County Courthouse, Carlisle, Pennsylvania.
You MUST obey the Order that is attached until it is modified or
terminated by the court after notice and hearing. If you disobey this Order,
the police may arrest you. Violation of this Order may subject you to a
charge of indirect criminal contempt which is punishable by a fine of up to
$1,000.00 and/or up to six months in jail under 23 Pa.C.S. 56114. Violation
may also subject you to prosecution and criminal penalties under the
Pennsylvania Crimea Code. Under federal law, 18 D.S.C. 52265, this Order is
enforceable anywhere in the United States, tribal lands, U.S. Territories and
the Commonwealth of Puerto Rico. If you travel outside of the state and
intentionally violate this Order, you may be subject to federal criminal
proceedings under the Violence Against Women Act, 18 U.S.C. 52261-2262.
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 TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET
LEGAL HELD. IF YOU CANNOT FIND A LAWYER, YOU 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 1990
The Court of Common Pleas of Cumberland County is required by law to
comply with the Americana 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.
JOANNE L. JOHNSON,
Plaintiff
VS.
DANIEL G. JOHNSON,
Defendant
IN THE COURT OF COMMON PLEAS
:OF CUMBERLAND COUNTY, PENNSYLVANIA
:NO. 99 - 5'14 CIVIL TERM
:PROTECTION FROM ABUSE
TEMPORARY PROTECTION FROM ABUSE ORDER
Defendant's Name: Daniel O. Johnson
Defendant's Date of Birth: 4/24/57
Defendant's Social Security Number: Unknown to Plaintiff
Name of Protected Person: Joanne L. Johnson
AND NOW, this JO Q M day of August, 1999, upon consideration
of the attached Petition for Protection from Abuse, the court
hereby enters the following Temporary order.
® 1. Defendant shall not abuse, harass, stalk or threaten any
of the above persons in any place where they might be found.
IN 2. Defendant is excluded from Plaintiff's residence located
at 952 Allen View Drive, Mechanicsburg, Cumberland County,
Pennsylvania, a residence which is owned solely by Plaintiff, and
from which Defendant moved on approximately July 23, 1999.
Plaintiff is granted exclusive possession of the residence.
® 3. Defendant is prohibited from having ANY CONTACT with
Plaintiff at any location, including, but not limited to any
contact at Plaintiff's place of employment, located at Repro, 777
East Park Drive, Harrisburg, Pennsylvania.
® 4. Defendant shall not contact Plaintiff by telephone or by
any other means, including through third persons.
? 5. Pending the outcome of the final hearing in this matter.
Plaintiff is awarded temporary custody of the following minor
child/ren:
Until the final hearing, all contact between Defendant and the
child/ren shall be limited to the following:
The local law enforcement agency in the jurisdiction where the
child/ren are located shall ensure that the child/ren are placed
in the care and control of Plaintiff in accordance with the terms
of this Order.
O 6. Defendant shall immediately relinquish the following
weapons to the Sheriff's Office or a designated local law
enforcement agency for the delivery to the sheriff's office:
Defendant is prohibited from possessing, transferring or
acquiring any other weapons for the duration of this order.
® 7. The following additional relief is granted:
The Cumberland County Sheriff's Department shall attempt to
make service at 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 Sheriff for service. The
Prothonotary shall not send a copy of this Order to Defendant by
mail.
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 Defendant has committed
another act of abuse or has engaged in a pattern or practice that
indicates continued risk of harm to Plaintiff.
Defendant is enjoined from damaging or destroying any
property owned jointly by the parties or owned solely by
Plaintiff.
Defendant is to refrain from harassing Plaintiffs
relatives.
® S. A certified copy of this Order shall be provided to the
police department where Plaintiff resides and any other agency
specified hereafter: Upper Allen Township and Lower Paxton
? 9_ THIS ORDER SUPERSEDES ? ANY PRIOR PFA ORDER AND ? ANY PRIOR
ORDER RELATING TO CHILD CUSTODY
10. THIS ORDER APPLIES IMMEDIATELY TO DEFENDANT AND SHALL REMAIN
IN EFFECT UNTIL MODIFIED OR TERMINATED BY THIS COURT AFTER NOTICE
AND HEARING.
NOTICE TO DEFENDANT
Defendant is hereby notified that violation of this Order
may result in arrest for indirect criminal contempt, which is
punishable by a fine of up to $1,000.00 and/or up to six months
in jail. 23 Pa.C.S. 56114. Consent of Plaintiff to Defendant's
return to the residence shall not invalidate this order, which
can only be changed or modified through the filing of appropriate
court papers for that purpose. 23 Pa.C.S. 86113. Defendant is
further notified that violation of this Order may subject him/her
to state charges and penalties under the Pennsylvania Crimes Code
and to federal charges and penalties under the Violence Against
Women Act, 18 U.S.C. SS 2261-2262. Any protection order granted
by a court may be considered in any subsequent proceedings
including child custody proceedings under title 23 (Domestic
Relations) of the Pennsylvania Consolidated Statutes
NOTICE TO LAW ENFORCEMENT OFFICIALS
This Order shall be enforced by the police who have
jurisdiction over Plaintiff's residence OR any locations where a
violation of this order occurs OR where Defendant may be located.
If Defendant violates Paragraphs 1 through 6 of this Order,
Defendant 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 cause, whether or not
the violation is committed in the presence of law enforcement.
Subsequent to an arrest, the law enforcement officer shall
seize all weapons used or threatened to be used during the
violation of this Order OR during prior incidents of abuse.
Weapons must forthwith be delivered to the Sheriff's office of
the county which issued this order, which office shall maintain
possession of the weapons until further Order of this Court,
unless the weapon/e are evidence of a crime, in which case, they
shall remain with the law enforcement agency whose officer made
the arrest.
BY THE COURT
Judge
Joan Carey
Attorney for Plaintiff
j.
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JOANNE L. JOHNSON,
Plaintiff
Vs.
DANIEL G. JOHNSON,
Defendant
:IN THE COURT OF COMMON PLEAS
:OF CUMBERLAND COUNTY, PENNSYLVANIA
:NO. 99 - 5 Sp? CIVIL TERM
:PROTECTION FROM ABUSE
PETITION FOR PROTECTION FROM ABUSE
1. Plaintiff's name is Joanne L. Johnson.
2. The name of the person, who seeks protection from abuse is
Joanne L. Johnson.
3. Plaintiff's address is 952 Allen View Drive,
Mechanicsburg, Pennsylvania.
4. Defendant is believed to live at 317 S. Market Street,
Mechanicsburg, Pennsylvania.
Defendant's Social Security Number is unknown to Plaintiff.
Defendant's date of birth is 04/24/57.
Defendant's place of employment is unknown to Plaintiff.
5. Defendant is Plaintiff's spouse.
6. Defendant has been involved in the following criminal
court action: Defendant has been charged with simple assault by
the Upper Allen Township Police from the incident occurring on or
about August 19, 1999.
7. The facts of the most recent incident of abuse are as
follows:
On or about August 19, 1999, Defendant grabbed Plaintiff
by the wrist, forcefully pulled her up the stairs, and grabbed
her by the neck. Defendant threw Plaintiff onto the bed, pulled
her onto the floor, and hit her in the chest several times.
Plaintiff yelled for her daughter to call the police, and
Defendant left the residence. Upper Allen Township Police have
filed simple assault charges against Defendant.
S. Defendant has committed the following prior acts of abuse
against Plaintiff:
a. In or around April 1999, Defendant became angry,
knocked over a lamp and threw an object at the couch where
Plaintiff was sitting, causing her to fear for her safety.
Defendant kicked Plaintiff in the knee.
b. In or around March 1999, Defendant tackled
Plaintiff, knocking her off of the bed and onto the floor causing
injury to her neck.
c. On or about August 1, 1998, Defendant kicked a table,
causing it to hit Plaintiff in the leg. Defendant followed after
Plaintiff and punched a wall, causing her to fear for her safety.
Plaintiff's friend called during this incident and Defendant
pulled the phone from Plaintiff and disconnected it, keeping
Plaintiff from asking for help. Plaintiff's friend contacted
Upper Allen Township Police who arrested Defendant for simple
assault and harassment.
d. In or around the Spring, 1998, Defendant punched
Plaintiff in the head several times. Defendant backed Plaintiff
into the bathroom where he hit her in the head causing her head
to hit the towel rack, resulting in bruising.
e. In or around December 1997, when Plaintiff, fearing for
her safety, ran upstairs to her bedroom and locked the door,
Defendant kicked open the door and shoved Plaintiff causing her
to fall to the floor. Plaintiff suffered soreness to her
tailbone.
f. Since the beginning of their relationship in 1997,
Defendant has abused Plaintiff in ways including the following:
choking, kicking, punching, and shoving the Plaintiff.
9. The following police departments or law enforcement
agencies in the area in which Plaintiff lives should be provided
with a copy of the Protection Order: Upper Allen Township and
Lower Paxton.
10. There is an immediate and present danger of further abuse
from the Defendant.
11. Plaintiff is asking the Court to exclude Defendant from
the residence at 952 Allen View Drive, Mechanicsburg,
Pennsylvania, which is owned by Plaintiff, and from which
Defendant moved on approximately July 23, 1999.
WHEREFORE, PLAINTIFF REQUESTS THAT THE COURT ENTER A TEMPORARY
ORDER, AND AFTER HEARING, A FINAL ORDER THAT WOULD DO THE
FOLLOWING:
A. Restrain Defendant from abusing, threatening, harassing, or
stalking Plaintiff in any place where Plaintiff may be found.
B. exclude Defendant from Plaintiff's residence and prohibit
Defendant from attempting to enter any temporary or permanent
residence of Plaintiff.
C. Prohibit Defendant from having any contact with Plaintiff,
either in person, by telephone, or in writing, personally or
through third persons, including, but not limited to any contact
at Plaintiff's place of employment, located at Repro, 777 E. Park
Drive, Harrisburg, Pennsylvania.
D. Prohibit Defendant from having any contact with Plaintiff's
relatives.
E. Order Defendant to pay the costs of this action, including
filing fees, service fees, and surcharge of $25.00.
F. Order Defendant to pay $250.00 to reimburse one of Legal
Services, Inc.'s funding sources for the cost of litigation in
this case.
G. Order the following additional relief, not listed above:
a. Defendant is enjoined from damaging or destroying any
property owned jointly by the parties or owned solely by
Plaintiff.
b. Defendant is to refrain from harassing Plaintiff's
relatives.
H. Grant such other relief as the court deems appropriate.
Order the police or other law enforcement agency to serve
Defendant with a copy of this Petition, any order issued, and the
Order for Hearing. Plaintiff will inform the designated
authority of any addresses, other than Defendant's residence,
where Defendant can be served.
Plaintiff prays for such other relief as may be just and
proper.
Respectfully submitted,
Jogn Cafey, Pl#lip Briganti,
Andrea Levy,
Attorneys for Plaintiff
LEGAL SERVICES, INC.
B Irvine Row
Carlisle, PA 17013
(717) 243-9400
Dated:
VERIFICATION
I verify that I am the Plaintiff as designated in the present
action and that the facts and statements contained in the above
Petition are true and correct to the best of my knowledge. I
understand that any false statements are made subject to the
penalties of 18 Pa.C.S. §4904, relating to unsworn falsification
to authorities.
Dated: ?'??- ?? n ( \J ?c ?(e
Jo? ne L. Johnson, Plaintiff
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SHERIFF'S RETURN - REGULAR
CASE NO: 1999-05282 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
JOHNSON JOANNE L
VS.
JOHNSON DANIEL G
CPL. TIMOTHY REITZ , Sheriff or Deputy Sheriff of
CUMBERLAND County, Pennsylvania, who being duly sworn according
to law, says, the within PROTECTION FROM ABUSE was served
upon JOHNSON DANIEL G the
defendant, at 20:50 HOURS, on the 31st day of August
1999 at 317 S. MARKET ST
MECHANICSBURG, PA 17055 CUMBERLAND
County, Pennsylvania, by handing to DANIEL G. JOHNSON
a true and attested copy of the PROTECTION FROM ABUSE
together with NOTICE OF HEARING AND ORDER, TEMPORARY
PROTECTION FROM ABUSE ORDER
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Aff idavit
Surcharge
18.00 So answers:
6.20 2
.00
8.00 R.`T omas ine, 5 eri
09/01/1999
by
Sworn and subscribed to before me
this j,L4L day of
19 gel A. D.
-P ro ?ono?ary
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Lov
JOANNE L. JOHNSON,
Plaintiff
VS.
DANIEL G. JOHNSON,
Defendant
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYLVANIA
:NO. 99 - 5282 CIVIL TERM
:PROTECTION FROM ABUSE
FINAL ORDER OF COURT
Defendant's Name: Daniel G. Johnson
Defendant's Date of Birth: 04/24/57
Defendant's Social Security Number: unknown to Plaintiff
Names of all Protected Persons: Joanne L. Johnson
AND NOW, this /4 40y"
day of September, 1999, the court having
jurisdiction over the parties and the subject-matter, it is
ORDERED, ADJUDGED, and DECREED as follows:
Plaintiff is represented by Joan Carey of LEGAL SERVICES, INC.;
Defendant is unrepresented but is aware of his right to have an
attorney. The parties agree that the following may be entered as
an Order of Court. Defendant, although agreeing that an Order
may be entered, does not admit to the allegation made in the
Petition.
? Plaintiff's request for a Final Protection Order is denied OR
® Plaintiff's request for a Final Protection Order is granted.
® 1. Defendant shall not abuse, stalk, harass, threaten
Plaintiff or any other protected person in any place where they
might be found.
N 2. Defendant is completely evicted and excluded from the
residence at 952 Allen view Drive, Mechanicsburg, Pennsylvania,
or any other residence where Plaintiff may live. Exclusive
possession of the residence is granted to Plaintiff. Defendant
shall have no right or privilege to enter or be present on the
premises.
? On [insert date and time], Defendant may enter the residence
to retrieve his/her clothing and other personal effects, provided
that Defendant is in the company of a law enforcement officer
when such retrieval is made.
® 3. Defendant is prohibited from having ANY CONTACT with
Plaintiff at any location, including, but not limited to any
contact at Plaintiff's place of employment, located at Keypro,
777 East Park Drive, Harrisburg, Pennsylvania.
® 4. Defendant shall not contact Plaintiff by telephone or by
any other means, including third parties.
? 5. Custody of the minor children, [names of the children
subject to the provision of this paragraph] shall be as follows:
(state to whom primary physical custody awarded; state terms of
partial custody or visitation, if any] (or see attached Custody
Order)
? 6. Defendant shall immediately turn over to the SheriffIs
Office, or to a local law enforcement agency for delivery to the
Sheriffs office, the following weapons used or threatened to be
used by Defendant in an act of abuse against Plaintiff and/or the
minor child/ren:
? 7. Defendant is prohibited from possessing, transferring or
acquiring any other weapons for the duration of this order. Any
weapons delivered to the sheriff under Paragraph 6 of this order
or under Paragraph 6 of the Temporary Order shall not be returned
until further Order of Court.
® S. The following additional relief is granted as authorized
by 56108 of this Act:
a. 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 Defendant has committed
another act of abuse or has engaged in a pattern or practice that
indicates continued risk of harm to Plaintiff.
b. Defendant is enjoined from damaging or destroying any
property owned jointly by the parties or owned solely by
Plaintiff.
C. Defendant is to refrain from harassing Plaintiff's
relatives.
d. The court costa and fees are waived.
? 9. Defendant is directed to pay temporary support for [insert
the names of the persons for whom support is to be paid]
as follows: (insert amount,
frequency and other terms and conditions of the support order]
This Order for support shall remain in effect
until a final support order is entered by this Court. However,
this Order shall lapse automatically if Plaintiff does not file a
complaint for support with the Court within fifteen days of the
date of this Order. The amount of this temporary order does not
necessarily reflect Defendant's correct support obligation, which
shall be determined in accordance with the guidelines at the
support hearing. Any adjustments in the final amount of support
shall be credited, retroactive to this date, to the appropriate
party.
? 10. The costs of this action are waived as to Plaintiff and
imposed on Defendant.
? 11. Defendant shall pay $* to Plaintiff as compensation for
Plaintiff's out-of-pocket losses, which are as follows:
OR
j ? Plaintiff is granted leave to present a petition, with
Ii appropriate notice to Defendant, to [insert the name of the judge
or court to which the petition should be presented] requesting
recovery of out-of-pocket losses. The petition shall include an
exhibit itemizing all claimed out-of-pocket losses, copies of all
bills and estimates of repair, and an Order scheduling a hearing.
No fee shall be required by the Frothonotary'a office for the
filing of this petition.
0 12. BRADY INDICATOR
1.0 Plaintiff or protected person(s) is a spouse, former spouse,
a person who cohabitates or has cohabited with Defendant, a
parent of a common child, a child of that person, or a child of
Defendant.
2.13 This Order is being entered after a hearing of which
Defendant received actual notice and had an opportunity to be
heard.
3.0 Paragraph 1 of this order has been checked to restrain
Defendant from harassing, stalking, or threatening Plaintiff or
protected person(s).
4.0 Defendant represents a credible threat to the physical
safety of Plaintiff or other protected person(s) OR
? The terms of this Order prohibit Defendant from using,
attempting to use, or threatening to use physical force against
Plaintiff or protected person that would reasonably be expected
to cause bodily injury.
® 13. THIS ORDER SUPERCEDES ® ANY PRIOR PFA ORDER AND ? ANY
PRIOR ORDER RELATING TO CHILD CUSTODY.
14. All provisions of this Order shall expire in one year.
NOTICE TO DEFENDANT
VIOLATION OF THIS ORDER MAY RESULT IN YOUR ARREST ON THE
CHARGE OF INDIRECT CRIMINAL CONTEMPT WHICH IS PUNISHABLE BY A
FINE OF UP TO $1,000 AND/OR A JAIL SENTENCE OF OP TO SIX MONTHS.
23 PA.C.S. 56114. VIOLATION MAY ALSO SUBJECT YOU TO PROSECUTION
AND CRIMINAL PENALTIES UNDER THE PENNSYLVANIA CRIMES CODE. THIS
ORDER IS ENFORCEABLE IN ALL FIFTY (50) STATES, THE DISTRICT OF
COLUMBIA, TRIBAL LANDS, U.S. TERRITORIES, AND THE COMMONWEALTH OF
PUERTO RICO UNDER THE VIOLENCE AGAINST WOMEN ACTION, 18 O.S.C.
52265. IF YOU TRAVEL OUTSIDE OF THE STATE AND INTENTIONALLY
VIOLATE THIS ORDER, YOU MAY BE SUBJECT TO FEDERAL CRIMINAL
PROCEEDINGS UNDER THAT ACT. 18 U.S.C. 55 2261-2262. IF
PARAGRAPH 12 OF THIS ORDER HAS BEEN CHECKED, YOU MAY BE SUBJECT
TO FEDERAL PROSECUTION AND PENALTIES UNDER THE "BRADY" PROVISIONS
OF THE GUN CONTROL ACTION, 18 U.S.C. 5922(0), FOR POSSESSION,
TRANSPORT OR RECEIPT OF FIREARMS OR AMMUNITION.
NOTICE TO LAW ENFORCEMENT OFFICIALS
The police who have jurisdiction over Plaintiff's residence
OR any location where a violation of this Order occurs OR where
Defendant may be located, shall enforce this order. An arrest
for violation of Paragraphs i through 7 of this Order may be
without warrant, based solely on probable cause, whether or not
the violation is committed in the presence of the police. 23
Pa.C.S. 56113.
Subsequent to an arrest, the police officer shall seize all
weapons used or threatened to be used during the violation of the
Protection Order or during prior incidents of abuse. The (insert
the appropriate name or title] shall maintain possession of the
weapons until further order of this Court. When Defendant is
placed under arrest for violation of the Order, Defendant shall
be taken to the appropriate authority or authorities before whom
Defendant is to be arraigned. A "Complaint for Indirect Criminal
Contempt" shall then be completed and signed by the police
officer OR Plaintiff, Plaintiffs presence and signature are not
required to file the complaint.
If sufficient grounds for violation of this order are
alleged, Defendant shall be arraigned, bond set and both parties
given notice of the date of the hearing.
BY THE COURT,
Edward E. Guido, Judge
If entered pursuant to the consent of Plaintiff and Defendant:
a la
Joanne Johnson Plaintiff Daniel G. Jo son, Defendant
Joan Ca fey, P lip Briganti,
Andrea Levy,
Attorneys for Plaintiff
LEGAL SERVICES, INC.
8 Irvine Row
Carlisle, PA 17013
(717) 243-9400
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RESULT OR
Joanne L. Johnson, IN THE COURT OF COMMON PLEAS OF
Plaintiff
CUMBERLAND COUNTY, PENNSYLVANIA
V. : CIVIL ACTION -LAW
Daniel G. Johnson,
NO.99-5282 CIVIL TERM
Defendant : PROTECTION FROM ABUSE
ORDER
AND NOW, this _day ofJuly 2000, upon consideration ofihe within Petition, the portions
of the Protection Order, dated September 14, 1999, which prohibit the defendant, Daniel Johnson,
from having any direct or indirect contact with the plaintiff, including but not limited to, telephone
and written communications, and prohibit the defendant from entering the plaintiffs residence, are
vacated.
In all other respects the Protection Order entered September 14, 1999, remains in effect.
Joan Carey
Attorney for Plaintiff
Daniel Johnson
Pro Sc Defendant
By the
Edward E. Guido, Judge
CUPLLD --rat.
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Joanne L. Johnson,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V. : CIVIL ACTION -LAW
Daniel G. Johnson,
NO. 99-5282 CIVIL TERM
Defendant : PROTECTION FROM ABUSE
PETITION FOR MODIFICATION
The plaintiff, Joanne Johnson, by and through her attorney, Joan Carey, of LEGAL
SERVICES, INC., represents the following:
1. The plaintiff and defendant are attempting a reconciliation.
2. The plaintiff desires that the defendant no longer be prohibited from having contact
with her, and that he no longer be enjoined from entering her residence.
3. The plaintiff desires that all other provisions ofthe Protection Order dated September
14, 1999, remain in effect.
4. Certified copies of the Order shall be provided to the Upper Allen and Lower Paxton
Township Police Departments.
WHEREFORE, the plaintiff requests that the Protection Order of September 14, 1999, be
modified to reflect the above terms.
Respectfully submitted,
Ptirlip C. ganti, Joan grey, Andrea Levy,
and Maryann Murphy, Attorneys for Plaintiff
LEGAL SERVICES, INC.
8 Irvine Row
Carlisle, PA 17013
Verification
The above-named plaintiff, Joanne Johnson, verifies that the statements made in the above
Petition are true and correct. The plaintiff understands that false statements herein are made subject
to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities.
Date: 7 `1 7 -C 0 ?; [L6?eui c ?ucdit?
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