HomeMy WebLinkAbout94-00880
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MeL~NIE ~. SAMPSON,
Plaintiff
IN THE COURT OF COMMON PLEAS of
CUMBERLAND COUNTY, PENNSYLV~NXA
CIVIL ACTION - LAW
v.
NO. g 80
CIVIL 1994
DAVID L. WILKERSON,
Defendant
PROTECTION FROM ABUSE
HMPQR.ABY. PH.Qre.en Y~QBDER
AND NOW, thiS.!;J/IJ... day of February, 1994, upon
presentation and consideration of the within Petition, and upon
finding that the plaintiff, Melanie A. Sampson, now residing at
529 1st Street, carlisle, Cumberland County, Pennsylvania, 17013
is in immediate and present danger of abuse from the defendant,
David L. Wilkerson, tha following Temporary Order is entered.
The defendant, David L. Wi lkerson, now residing at 74 East
5th Strllet, Collegeville, Cheater County, Pennsylvania, 19016 is
hereby enjoined from physically abusing the plaintiff, Melanie A.
Sampson, or placing hor in fear of abuse.
The defendant is ordered to stay away from the plaintiff's
residence located at 529 1st Street, Carlisle, Cumberland County,
PennsYlvania, a residence which is leased solely by the
plaintiff, which is not owned or leased by the defendant.
The defendant is hereby notified that if he violates this
Order, he may be in Indirect criminal contempt which is
puniShable by a fine not to e~ceed $1,000.00 and/or by 8 sentence
of up to gl~ months in jail and any other appropriate punishment.
Reeumptlo/\ of co-residence on the part of the plaintiff and
defendant aha 11 not nu 11 i fy t.ho prov j 6 i ona of the' court order
dlreGtin~ the defendant to refrai/\ from abusing the plaint.iff,
The defendant is ordered to refrain from having any direct
or indirect contact with the plaintiff including, but not limited
to, telephone und written communications.
The defendant is enjoined from harassing and stalking the
plaintiff and from harassing the plaintiff's family.
The defendant is enjoined from entering the plaintiff's
schoo 1 .
Thi. Order ehall remain in effect until a final order ie
entered in this ca~e. A hearing shall be held on this mattlr on
"..:)t JLt<LI'l '1f
the ,:1~tJ-._, day off, 1994, st."-:LOP.H_P.m., in Courtroom No...~,
Cumberland County Courthouse, Carlisle, Pennsylvenia.
The pIa i nt iff may proceed .tn formA J)A,UDtI.r.J.I pend i ng a
further order after the hearing.
The Cumberland County Sheriff's Department Shall attempt to
make service at the plaintiff's request, but service may be
accomplished under any applicable rule of Civil Procedure.
The Pennsylvania State Police and the Carlisle Police
Departments shall be provided with a copy of thie Order by the
plaintiff's attorney. This Order shall be enforced by any law
enforcement aQency where a violation occurs by arrest for
Indirect criminal contempt without warrant upon probable cauee
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, ths defendant shall bl
taken without unnecessary delay before the court that i.auld the
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v.
IN THE COURT OF COMMON PLE~S OF
CUMBERL~ND COUNTY, PENNSYLVANIA
CIVIL ~CTION - LAW
NO. ? SO CIVIL 1994
PROTECTION FROM ABUSE
MELANIE A. SAMPSON,
Plaintiff
DAVID L. WILKERSON,
Defendant
NOT ICE
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 agajnot you. You are warned that if you
fail to do so the Court may proceed without you, and a jUdgm$nt
may be entered against you by the Gourt 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.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU
DO NOT HAVE A LAWYER OR C~NNOT ~FFORD ONE, GO TO OR TELEPHONE THE
OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
COURT ADMINISTRATOR, 4th FLOOR
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PENNSYLVANIA 17013
TELEPHONE NUMBER: (717) 240-6200
v.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLV~NIA
CIVIL ACTION - LAW
NO. 8' f(J CIVIL 191)4
PROTECTION FROM ABUSE
MELANIE A. SAMPSON,
Plnintiff
DAVID L. WILKERSON,
Defendant
f..E.UUQtLf.QIlJ'ftQU.CH 1Y.E.J)ftI).E.B
AHILQ.UIl.mD.Y.
RELIEF UNDER THE PROTECTION FROM ABUSE
ACT, 23 P.S. I 8101 et eeQ.
A.._.ABU6.E
1. The plaintiff is an adult individual whose permanent
address is 629 1st street, Carli$le, Cumberland County,
Pennsylvania, 17013.
2. The defendant is an adult individual residing at 74
East 5th Street, Collegeville, Chester County, Pennsylvania,
19016.
3. The defendant is the plaintiff's former intimate
partner.
4. Since appro~imately December 191)3, the defendant has
attempted to cause and has intentionally, knowingly, or
reckleesly caused serious bodily harm and by physical menace haa
placed the plaintiff in fear of imminent serious bodily injury.
This has includod but is not limited to the following epecific
instances of abuse:
a. On or about February 16, 1994, the defendant
telephoned ths plaintiff and threatened to kill her.
b. On or abQut February 14, 1994, the defendant
became angry, pulled back his left hand and backhanded the
plaintiff across the right side of her face, causinQ a black eye
and bru i sed cheek. The de fendant t.hen threatened to kill the
plaintiff .
c. On or about February 12, 1994, the defendant
became enraged, and threatened to kill the plaintiff if she
"found someone else". The defendant then shoved the plaintiff,
who ie seven months pregnant, with his body caualng the plaintiff
to hit the wall with enough force to leave an indentation in the
wall.
d. On or about February 11, 1994, the defendant
became enraged and struck the plaintiff in the face with the back
of his hand. The force from the defendant's blow was so gre8,t
that it forced the plaintiff down into the bed where the
defendant initiated se~ual int~rcourse in spite of the
plaintiffs' refusal.
e. On or about Oecember 25, 1993, when a male friend
of the plaintiff dropped off Christmas presents for the plaintiff
and her child, the defendant became enraged and threatened to
kill him, causing the plaintiff to fear for her safety and that
of her ch i 1 d .
f. On or about December 22, 1993, the defendant
threatened to kill the p I a i nt iff if she did not have sexua 1
intercourse with him. The plaintiff left her residence and went
to stay in a domestic violence shelter.
5. The plaintiff believes and therefore avers that she is
in immediate snd present danger of abuse from the defendant and
that she is In need of protection from such abuse.
e. The plaintiff desires that the oefendant be prohibited
from having any direct or indirect contact with the plaintiff
including, but not limited to, telephone and written
communicatione.
7. The plaintiff desires that the defendant be enjoined
from haraseing and stalking the plaintiff, and from harassing the
plaintiff's family.
8. The plaintiff desires that the defendant be restrained
from entering her school.
flL~IIQm/.E'L.Efi.D
9. The plaintiff aake for attorney fees to be paid to
Legal Services, Inc., pursuant to the Protection from Abuse Act.
CL__S IAT!JJLJ.O.. .fROOf,.EJLI1:I.E9HMA .EAVP.fB.lf1
10. The plaintiff goes to school, and receives public
assistance of $316.00 per month.
11. The plaintiff does not have funds available to pay the
fees for filing and service of this lawsuit.
WHEREFORE, pursuant to the provisions of the "Protection
from Abuse Act" of October 7,1976, 23 P.S. .6101 gj; .llG., 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 or placing her in fear of
abuse.
2. Ordaring the defendant to refrain from havinll
any dirflct or indirect contact with the plainti"
including, but not limited to, telephone and
written communlcationej
3. Ordflring the defendant to refrain from
harassing and stalking the plaintiff and from
harassing the plaintiff's familYj
,4. Prohibiting the defendant from sntering the
plaintiff's echool j
5. Orderil\g the defendant to stay away from the
residence located at 529 1st Street, Carli.le,
Cumberland County, Penneylvania, 17013 which the
parties havfl never sharedj
6. Ordering the defendant to stay away from any
residence the plaintiff may in the future
establish for herself;
B. Schedule a hearing in accordance with the
prOVisions of the "Protection from Abuee 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 or placing her in fear of
abuse.
2. Ordering the defendant to refrain from havinQ
any direct or indirect contact with the plaintiff
inoluding, but not limited to, telephone and
written communications.
3. Ordering the defendant to refrain from
harassing and stalking the plaIntiff and from
harassing the plaintiff's family.
4. Prohibiting the defendant from entering the
plaintiff's school.
5. Ordering the defendant to stay away from the
reeldonce located at 529 1st Street, Carlisle~
Cumberland County, Pennsylvania, 17013 which the
part les have never shared.
6. Ordering the defendant to stay away from any
residence the plaintiff may in the future
establish for herself.
7. Ordering the defendant to psy attorney fees
to Lega I Serv ices, Inc. I pursuant to the
Protection From Abuse Act.
The plaintiff further asks that this Petition be filed and
served without payment of costs, pending a further order at the
hearing, and that a certified copy of this Petition and Order be
delivered to the Pennsylvania State Police and the Carlisle
Police Department.
The plaintiff prays for such other relief as may be just and
proper.
,
,
Respectfully submitted,
.r" ~
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,/14f! ':rT~~_tL__._---
Philip C. Briganti
Attorney for Plaintiff
L~G~L SERVICES, INC.
a Irvine Row
Carlisle, PA 17013
(717) 243..9400
The abqve-named plaintiff, Melanie Bamp.on, verifie. that
the .tatementa made in the above Petition are true and correct.
The plaintiff under.tend. that falNe .tatement. her.in are mad.
.ubject to the penaltie. of 18 Pa. C.B. section 4904, relating to
un.worn falaiticat!on to authoritie..
Patel d J i),a)Cli--
"'\'l.-:'..o-"'~' ~~...:.\,,\,_~ <-r......~-
MIlania Bamp.on, Plaint! f
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MELANIE A. SAMPSON,
Plaintiff
v.
IN THE COURT OF COMMON PLE~8 OF
CUMBERL~ND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 880 CIVIL 109.
DAVID L. WILKERSON,
Defendant
M.Qll..QtLf.QfL~.QIUIH!JAtiC.E
The plaintiff, by and through her attorney, Joan Carey of
Legal Servicee, Inc. etates the following:
1. On the 24th day of February, 1994, the plaintiff filed a
Protection From Abuse action and the court entered a Temporary
Protective Order schedulino a hearing for the 28th day of
February, 100..
2. A copy was given to the Cumberland County Sheriff to
eervo upon the defendant and the Sheriff has deputized Montgomery
County Sheriff's Department to serve the defendant.
3. Legal Services, Inc. has contacted Montgomery County
Sheriff's Department and has been informed that the defendant has
not been served at this time.
4. The plaintiff requeets that the Temporary Protective
Order remain in effect pending further Order of Court.
WHEREFORE, the plaintiff requests that an Order for
continuance be entered and that pending further Order of Court
..
MELANIE A. SAMPSON, I IN THE COURT OF COMMON PLEAS OF
plaintitt I
I CUMBERl~ND COUNTY, PENNSYLVANIA
v. I
I CIVIL ACTION - LAW
DAVID L. WILICBRSON, I
Defendant I NO. 880 CIVIL 1994
I
I PROTECTION FROM ABUSE
ORDER FOR CONTINUANCE
AND NOW, thb
'it)..
\ J )/ /
of - tL/l.r' A.,
, 1994, upon
day
ooneideration ot the attached Motion tor continuanoe, the hearing
echeduled tor March 4, 1994, in Courtroom No.2 ot the Cu~berland
hae been oontinued
county Courthouee, carliele, Penneylvania
.(). '-It I
until the .J.J.::.. day ot . I (;, 1 (' -', 1994,
The Temporary Protective Order ot
in ettect pending turther
at/3() ('.m.
Fe y 24,
1994, remain.
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MILANII A. SAMPSON,
Plaintiff
v.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 880 CIVIL 1994
DAVID L. WILRERSON,
Defendant
MOTION FQR CO~TINUANCE
The plaintiff, by and through her attorney, Joan Carey of
Legal Service., Ino. .tate. the followingl
1. On the 24th day of February, 1994, the plaintiff filed a
Protection From Abu.. action and the court entered a Temporary
Proteotive Order .ohedulinq a hearinq for the 28th day of
February, 1994.
2. A copy wa. qiven to the Cumberland County Sheriff to
.erve upon the defendant and the Sheriff haa deputized Montqomery
County Sheriff" Department to serve the defendant.
3. Legal service., Inc. contaoted Montgomery County
Sheriff's Department and waR informed that the defendant ha. not
been served at that time.
4. A Order for Continuance waR entered and a new hearinq
WaG .oheduled for March 4, 1994 at 10130 a.m.
On March 4, 1994, Legal services, Ino. was aqain informed
that the Montgomery County Sheriff's Department has not been able
to .erve the defendant.
6. The plaintiff request. that the Temporary Proteotive
order remain in effect pendinq further order of Court.
~
..ILUII A. .UJlOI I II THI COU.T or CONICOI .LIA. or
.1aintUf I
I CUN...LAlD COUITY, .....YLVAlIA
I CIVIL ACTIOI - LAW
Y. I
I 10. ..0 CIVIL ~"4
DAVID L. "U....OI, I
Defen'ant I ..ot.CTIOI r.o.. lIUII
DID'. '01 COITIWU&Mal
11 t:A
AND NOW, thie -LJL- day ot Maroh, 1994, upon ooneideration
ot the attaohed Motion tor continuanoe, the matter .oheduled for
hearinq on March 17, 1994, in Courtroom No.2 ot the cumberland
County Courthou.e,
until the le,t.k
carli.le, penn.ylvania ha. been continued
day ot ~\.~1. , 1994, at 'l),4'i c\ .m.
proteotive Order will remain in ettect for a
The Temporary
period of one year or until a tinal Order i. entered in thi.
,
ca.e.
A copy of thi. Order for continuanoe will be provided to the
carli.l_ and penn.ylvania State Polioe
plaintitt'. attorney.
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DAVID L. WILRERSON,
Defendant
1 IN THE COURT OF COMMON PLEAS OF
1
1 CllMBERLAND COUNTY, PENNSYLVANIA
1 CIVIL ACTION .. LAW
1 NO. 880 CIVIL 1994
1
1
1 PROTECTION FROM ABUSE
MlLANIE A. SAMPSON,
Plaintiff
JlO'1'IOM .0. QOHIMUua.
The plaintiff by and through her attorney, Joan carey ot
Legal servioe., Ino., state a the followingl
1. A Temporary proteotive Order was issued by thia Court
on Feb~uary 24, 1994, soheduling a hearing for February 28, 1994,
at 2100 p.m.
2. A oopy ot the Order was given to the Cumberland County
Sheriff to serve upon the detendant, and the Sheriff has deputized
the Montgomery county Sheriff'. Department to .erve the
defendant.
3. The plaintift has had to request several oontinuances
of the hearing in this matter, because the Montgomery county
Sheriff'. Department has been unable to make servioe upon the
detondant.
4. PUrsuant to the moat recent continuance, the hearing i.
pre.ently scheduled for March 17, 1994, at 1130 p.m.
5. On March 16, 1994, plaintiff'S oounsel was informed by
the Montgomery county Sheriff's Department that it had learned
the detendant would be out ~t the state ot Pennsylvania tor
approximately two weeks. The Sheriff'. department believe. it
will be able to .erve him onoe he arrives baok in Pennsylvania.
WHEREFORE, the plaintiff requests that thie Court oontinue
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SHERIFF'S RETURN
COST. PROTHONOTARY.,
DEfENDANT
DOCUMENT SlRVED
INDIVIDUAL SERVED
RELATIONSHIP TO DEfENDANT
DATE AND PREVAILING TIME
LOCATION .
Q- 1240
David L. Wilkerson
Civil
Bob Kurylo
~:lnp loyer
March 10, 1994 @ 10125
Montgomery County Court House
THE ABOVE DOCUMENT WAS SERVED ON THE DEfENDANT AS PIIt INfORMATION LISTED AIOVIIN
THE COUNTY Of MONTGOMERY, COMMONWEALTH Of PENNSYLVANIA,
AffiRMED AND SUBSCRIBED BEfORE ME ON
THIS DAY,
April 7, 1994
50 ANSWERS,
.::JL~~'~~U _ ~I II ~
NOTARY PUBLIC
("~,-.4. 61 ~
~ fRANK p, LALLEY
SHERiff Of MONTGOMIRY COUNTY
('-'-''''..'''' ......"..-.....-. "
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DEPUTY SHIRIf'
AI Smith
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Q- 1 Z40
March 19, 199/,
NUMBER
DATE
r-
MeLanis A. Sampson
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF MmHGOMERY
V5
David J.. Wilkeuun
'--
74 ~. lth Street,
~oLleMsvlllle, PA
NO SERVICE
SO ANSWERS
. , , , , , ~Ri'.,'!K r LALLtl
SHERIFF Of MONTGOMERY COUNTY
BY
Capaldo
oepuTY
MIMO,
]-L'-94 @ 191301 Not home nowop"p"rs in front of door.
Neighbor has lIot oeen anyon.. In Apt G 102 in weeks.
3-16-94 @ 071501 No answer, papero still there.
Per Bob Kuryls, 8ubJecto employer. Subject has bean out of state
for tho past 2 weeks.
ID 'or.. 0)2.1 Mo,16
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Meldni,e A. fllllrlJe\Hl
'IS.
David L. WilkerBon
:-la. .__....tl.!!.~: Iv I.LD~..l21..L.._--. ;lI.._._.
:;'ow.. March 10 I 1 (Jl)4
:9_ !, S:'iZ:;U::::;- OF C~~,l'3za!..A.'fI) COT..~'l'Y, PA.. dQ
llcnby dcpl.lC::l rl:l4 !b.c".tJ' of
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MI~ANIB A, SAMPSON,
Plaintiff
VI.
IN THE COURT OF COMMON P~EAS or
CUMBERLAND COUNTY, PENNSY~VANIA
NO, 94 -880 CIVI~ TIRM
PROTECTION FROM ABUSR
DAVID ~. WI~KBRSON,
Defendant
f1!.Q1.B.Q'1' l-Y.B ._O.R.OJ.R
AND NOW, this~~'9. day of April, 1994, upon consideration
of the Consent Agreement of the parties, the following Order is
entered;
1. The defendant, David L. Wilkerson, is enjoined from
physically abusing the plaintiff, Melanie A: Sampson, or from
placing her in fear of abuse,
2. The def,ndant is enjoined from having any direct or
indirect contact with the plaintiff including, but not limited
to, t.elephone and written communications.
'3. The defendant is ordered to refrain from harassing and
stalking the plaintiff and from harassing the plaintiff's family.
4. The defendant is prohibited from entering the
plaintiff's place of employment or school.
5. The defendant, ie ordered to stay away from the
residence located at 529 1st Street, CarliSle, Cumberland County,
Pennsylvania, which the parties have never shared,
6. The defendant, is ordered to stay away from any
residence the plaintiff may establish for herself in the future.
7. This Or.der shall remain in effect for a period of one
year.
8. The Middlesex and Pennsylvania State Police Departments
.
will b. provid.d with a copy of thiB Order by attorn,ys for the
plaintiff and may .nforce this Order by arreat for indirect
criminal contempt without warrant upon probable cauae that this
Ord.r has been violated, whether or not the violation i.
committed in the pre..nce of the police offic.r. In the ev.nt
that an arre.t iB mad. under this B.ction, the defendant ahall
not b. taken to jail but ahall b. taken without unneceseary delay
b.for. the Court that issued the Order. When that Court ia
unavailable, the defsndsnt Bhall bo arraigned before a district
JUBtice who Bhall set bail according to the provisions of Chapt.r
4000 of the Pennsylvania RuleB of Criminal
Section 6113).
(23 PS
B
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MELANIE A. SAMPSON,
Plaintiff
IN THI COURT OF COMMON PLIAS OF
CUMBBRLAND COUNTY, PBNNSYLVAHIA
NO. 94 -860 CIVIL TIRM
I
I PROTECT JON FROM ABUSE
I
I
C9N~iNt^QR2~MlliT
vs.
I~
8
DAVID L. WILKINSON,
Defendant
This Agreement is entered on this
day of April, 199.,
by the plaintiff, Melanie A. Sampson and the defendant, David L.
Wilkerson. The plaintiff is represented by Joan Carey, of Legal
Services, Inc., the defendant is represented by Gary Lewis, of
Keenan, Ciccitto, Brant, and Hixson. The parties agree that tha
following may be entered ao an Order of Court.
1. The defendant, David L. Wilkerson, agrees to refrain
from abusing the plaintiff, Melanie A. sampson or from placing
her in fear of abuse.
2. The defendant agrees not to have any contact with the
plaintiff, including but not limited to, entering the plaintiffls
place of employment or school.
3. The defendant sgrees not to harass or stalk the
plaintiff or harana the plaintiff's relatives.
.. The defendant agrees to stay away from the residenoe
located at 529 1st street, Car.lisle, Cumberland County,
Pennsylvania.
5. The defendant agrees to stay away fr.om ~ny residence the
Plaintiff may establish for. herself in the future.
6. The defendant, although entering into this Agreement,
does not admit the allegations made in this Petition.
7. The defendant understande that the Protective Order
l,i:r~f)l. 61f-HV' CJ;'n, ."1.';.
;1.,:at.U):i!lb
enter'd In thla .~tter ahall bo in effenl tu~ . v~(iod at one
y..sr.
8. The defendant under>>tandN that thl. order will b.
en'(lrce.ble in the aame mannar all t.he Court'. prior Telllporary
Proteotiva Order entered in this ca...
WHBRIJORI, the putiee request that 8n Order of Court be
entered to refloct tho above ter...
~~\\~~~':~mpt ,.'~~~~~~r\'/'
~..,~z:.:... .
n Cilley
ttorney for aintitl
LIOAL BIRVJCIS, I"C.
8 Irvine ROW'
Carlisle, fA 17013
('/17) 243-UOO
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~'e,:;L~/dat- -=~
~d r,. wilkeraon, Def.ndant
.J.~~-~
At.torney for Oef ndant
~e.nan, Ciccitto, Brant, and
Htxllon
376 S. Haln St, P.O. BOK 376
Collegllv il. 18, PA , 194 36
(610) .89-6170
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