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Home My WebLink About94-01213 ~ .I o <\ , ^'o ',I r.I I "2:" G"''lJI.;, C ~a: (~;Ji~,;~q~ ~"1 C. I,J~ v. IN THE COURT OF COMMON PLEAS DAUPHIN COUNTY, PENNSYLVANIA No. ~C1C\ S 199/f CIVIL ACT\ON - LAW ALMA LAWSON, Petitioner TERRY LAWSON, Respondent PROTECTION FROM ABUSE NOTICE TO DEFEND YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must appear at the hearing scheduled herein. You are warned that if you fail to do so the case may proceed without you and an Order may be entered against you for the relief requested in the Petition. You may lose money or property or other rights important to you. If a copy of the obey it until the hearing. arrest you. TEMPORARY ORDER is attached, you must If you do not obey it, the police can YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. YOU HAVE A RIGHT TO HAVE AN ATTORNEY REPRESENT YOU AT THE HEARING. IF YOU DO NOT HAVE AN LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU MAY GET LEGAL HELP. AVYSO PARA DEFENSA USTED HA SIOO DEMANDAOO EN LA CORTE. si usted quiere defenderse de las reclamaciones descritas en las paginas siquientes usted debe asistir a la vista que esta citada en esta. Usted esta siendo advertido de que si falla en asistir a la vista el caso procedera sin usted y una Orden puede ser expedida en contra suya para el remedio solicitado en 1a peticion. Usted puede perd'r dinero 0 propiedad u otros derechos importantes para usted. Si la copia de una Orden Provisional esta adjunta usted debe obedecer1a hasta que la vista se lleve a cabo. si usted no no la obedece la policia lo puede arrestar. Usted debe llevar este documento a su abogado enseguida. Usted tiene derecho a tener un abogado que lo represente en la vista. Si no tiene un abogado 0 no tiene dinero para uno; vaya llame a la siguiente oficina donde le informaran donde consequir ayuda legal. DAUPSYN COUNTY LAWYER REFERRAL SERVICB 213 North Front street HarriSburg, PA 17101 (717) 232-7536 TEMPORARY PROTECTIVE ORDER AND NOW, this II tJj day of /J1 t:V1 C-t. presentation and consideration of the within Petition, ordered as follows: , 199"', upon it is hereby ALMA LAWSON, Petitioner . . IN THE COURT OF COMMON PLEAS DAUPHIN COUNTY, PENNSYLVANIA No. ~~C:t S 199'f CIVIL ACTtON - LAW . . v. TERRY LAWSON, Respondent . . PROTECTION FROM ABUSE NOTICB TO PBTITIONER OR WITNESS: IKMEDIATELY CALL THB POLICB (911) IF THE RESPONDENT VIOLATES THIS PROTECTIVE ORDER. 1. Respondent is prohibited from approaching, abusing, threatening, or harassing Petitioner, either physically or verbally, wherever she may be. 2. Respondent is evicted from, and shall immediately upon being served herewith, remove himself from the premises at 233 South 2nd street, steelton, Dauphin County, Pennsylvania, which premises are hereby restored to the exclusive possession and control of petitioner. If Respondent is present at the subject premises when this Order is served or enforced, Respondent shall be escorted immediately therefrom by any deputy sheriff or other law enforcement officer performing such service or enforcement, pending further order of this Court. Respondent is also prohibited from entering or attempting to enter said residence, or any other residence Petitioner may choose to establish. 3. Respondent is prohibited from contacting Petitioner in any manner, including entering or telephoning Petitioner's home, school or places of employment. 4. Respondent is prohibited from stalking Petitioner as that term is defined in the Crimes Code, 18 Pa. C.S. ~2709. 5. Respondent is directed to refrain from all harassing communication with Petitioner's relatives. 6. The Prothonotary, Sheriff, and local law enforcement agencies are directed to accept, file and serve all copies of this Petition and Order without prepayment of costs. 8. This Order shall be enforced by any law enforcement agency in any county where a violation occurs. As provided in 23 Pa. C.S. S6113(a) of the Act, "[a]n arrest for violation of an order issued pursuant to this act may be without warrant upon probable cause whether or not the violation is committed in the presence of the police officer." 9. Respondent is hereby notified that if he violates this order, he may be held in indirect criminal contempt which is punishable by a fine of up to $1000.00 and/or by a jail sentence of up to six (6) months. 10. This Order shall remain in full force and effect until further Order of the Court. 7. A certified copy of this Order shall be served on the Harrisburg city police Department if said department is within the appropriate jurisdiction for Petitioner's residence and/or school or place of employment, or on Dauphin county Control as to any jurisdiction within Dauphin county but outside the city of Harrisburg. Should the police come into contact with Respondent, and should Respondent allege that he has not been served with this order, the police officer shall immediately serve the Order upon him. ~\~ 11. A ~arinqr\n this matter is sChed~1Cx~orA day of (H"( , 1991/, at . , .M. , in Court Room No.5, Dauphin County Courthouse, Front & arket streets, Harrisburg, Pennsylvania. BY THB COURT: )~~!~~~~f1H.I jl~&~~t~:fJJJJ ,J . DISTRIBUTION Petitioner Sheriff for Respondent Dauphin County Control cumberland County Court of Common Police Department in Cumberland File I~V' II 19~ Plea~_.,..; .",',!".,>.t ::r, ;:"r:?g(1i.r.~1 is a \ r.~ '. ."~J '. .:' I . "~';" (jf me onglna\ . ,"\".,C "--"-')' \. c., ,'. .. ~ ,'.. I Iii........ . ~;,-:.!.d C-, -I- ()Jr;wJ -- f::-_._- Proti1ol\otary ALMA LAWSON, . IN THE COURT OF COMMON PLEAS . Petitioner . DAUPHIN COUNTY, PENNSYLVANIA . : qqq v. No. S 199'1 CIVIL ACTION - LAW TERRY LAWSON, : Respondent . PROTECTION FROM ABUSE . PETITION POR PROTECTION PROM ABUSE TO THE HONORABLE JUDGES OP SAID COURT: The Petition of Alma Lawson, by her attorneys, Laurence E. Norton, II, Esquire and Central Pennsylvania Legal Services, pursuant to the Protection from Abuse Act, 23 Pa. C.S. 556101, ~ ~., ~ amended, respectfully represents as follows: 1. Petitioner is an adult individual presently residing at 233 South 2nd street, Steelton, Dauphin County, pennsylvania. 2. Respondent is also an adult who is presently residing at 233 South 2nd street, Steelton, Dauphin County, Pennsylvania. 3. The relationship between Petitioner and Respondent is that of husband and wife. 4. Both Petitioner's and Respondent's names are on the deed for the residence in paragraph number 1 above. 5. Petitioner is employed at United Parcel Service, 1831 South 19th Street, Harrisburg, Pennsylvania, and is also employed at National RX Services, located at 5073 Ritter Road, Mechnicsburg, Pennsylvania, with approximate net earnings of $300.00 per week. 7. a, On or about March 10, 1994, Respondent and Petitioner were arguing. Respondent then grabbed the phone away from Petitioner. They wrestled over the telephone, He unplugged the phone. She threw phone down on the floor. Respondent next grabbed Petitioner and choked her. She threatened to call the police. Respondent then shoved and pushed Petitioner several times as she tried to get dressed to leave their apartment. Respondent told Petitioner that she was not going to leave the apartment. Respondent wrestled with Petitioner and threw her onto the floor. As Petitioner lay on the floor, Respondent attempted to rip Petitioner's sweater off of her body. When Respondent could not get the sweater off Petitioner, he grabbed the front of the sweater, lifted her off the floor and caused her to bite her tongue, and bruise her lip. He then lifted her up by her collar off the floor and threw her back down onto the floor. Petitioner ran into the kitchen and picked up a shovel and threatened to hit Respondent with the shovel. Petitioner called the police for assistance. Respondent was charged with simple assault and domestic violence. 7. Respondent has engaged in abusive conduct toward Petitioner as such conduct is defined in the Act. Examples of said conduct include, but are not limited to, the following: b. On or about September 23, 1993 Respondent argued with Petitioner. Respondent next pulled the covers off Petitioner, verbally abused her, and told her to leave the apartment. As Petitioner got off the bed, Respondent told Petitioner that she was not leaving. Respondent then grabbed Petitioner forcefully by her arms, shoved her, causing her to fall onto the bed. Respondent then approached Petitioner in a menacing manner, and screamed in her face. Respondent next verbally abused Petitioner, punched the dresser, breaking his hand and went to bed. /!. On or about September 22, 1993 Petitioner argued with Respondent and threatened to stop her from going to work. Petitioner next ran out of the apartment to her car. Respondent chased Peti tioner, grabbed her forcefully, hurting her arm, and stood in front of her car. Respondent told Petitioner that she was not going to work until she promised that she would not confront his girlfriend. Petitioner agreed and was then able to get into her car and go to work. o. On or about September 14, 1993 Petitioner came home and checked her answering machine for messages. Respondent had left several messages on the machine verbally abusing Petitioner and threatened to kill her. In one of the messages, Respondent told Petitioner that she should have been home, that he was going to be on America's most wanted, and that he was going to kill her and kill himself. Respondent also demanded that Petitioner call him as soon as she got home. Petitioner called Respondent. Respondent stated that he was not going to allow her to go out anymore. 6. Respondent is employed at AMP, Incorporated, Harrisburg, Pennsylvania, with approximate net earnings of $375.00 per week. e. .f' Petitioner hung up on Respondent. Respondent then called Petitioner again, and said that he was coming home. When Respondent came home, he argued with Petitioner and asked her to leave. As she attempted to leave the apartment, he told her that she was not going any where, and stood in the doorway in a menacing manner, preventing Petitioner from leaving the apartment. On Thanksgiving of 1992, Respondent grabbed Petitioner by her hair and threw her onto the floor. On July 4, 1992 Respondent grabbed Petitioner by the hair and threw her onto the floor. There have been numerous other incidents where Respondent has treated Petitioner abusively to one degree or another, including, but not limited to, threats to cut her face so that on one would want to be with her. Respondent has also forcefully grabbed Petitioner preventing her from leaving the house. Respondent in the past, has punched Petitioner in the mouth and has choked her. 8. Petitioner believes that she is in immediate and 9, present danger of further abuse and harassment from Respondent, and that she is in need of, and entitled to, protection from such abuse. WHEREFORE, pursuant to the protection from Abuse Act, Petitioner prays your Honorable Court to: I. Immediately enter a temporary order, pursuant to section 5(b) of the Act, 23 Pa. C.S. ~6107(b); A. Directing Respondent to refrain from approaching, abusing, harassing, or threatening petitioner, physically or verbally, wherever she may be, l' ',',. B. Evicting Respondent from Petitioner's current residence and restoring such residence to the exclusive possession and control of Petitioner; C. Excluding Respondent from any residence which Petitioner may occupy during the pendency of this Order: D. Prohibiting Respondent from having any contact with Petitioner, including entering or telephoning Petitioner's home, school or place of employment: E. Prohibiting Respondent from stalking Petitioner as that term is defined in the Crimes Code, 18 Pa. C.S. ~2709: and F. Directing Respondent to refrain from all harassing communication with Petitioner's relatives. II. After hearing, and pursuant to Section 1 of the Act, 23 Pa. C.S. ~6108, enter a final protection order continuing the relief set forth above, for a period of one (1) year, and further requiring that Respondent: A. Pursuant to Section 5(d) of the Act, 23 Pa. C.S. ~6107(d), pay all taxable costs of this action: B. Pay attorneys fees for the use of the County of Dauphin in the amount of $250.00: C. Pay Petitioner $28.00 per week for her support and care until a final Order of Support is entered by Domestic Relations; D. Peacefully retrieve any personal possessions with the aid of a local law enforcement officer, said officer to be compensated, if payment is required, by Respondent; and E. Enroll in private or publicly funded professional psychological counselling concerning anger control and Respondent's history of abusive conduct, including any substance abuse which may be involved. Respectfully submitted, CENTRAL PENNSYLVANIA LEGAL SERVICES , J -( (-")'1 7 BYI ' <-,,- urence E. Norton, II, Esqu re 0'ttorneys for Petitioner , 213-A North Front street t Harrisburg, PA 17101 (717) 232-0581 VERIFICATION I am the Petitioner in this Petition for Protection from Abuse. I do not have the funds available to pay the costs of filing and service of this action at the present time. I verify that the statements made in this Petition are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. S4904, relating to unsworn falsification to authorities. ?,-)\-qL\ Date ~ OIW\!j ddl1~ Alma Lawson, Petitioner -, , .- r~ ~!. . ~ -- '"")' -:r ~ .~ .....:.; " c" ..... :> . - -- .~ t:: "'"' o b r ~ 0- - r .",.. 11- i m ,. ':lL = 0 c:t, ,~ :::> q (J .. ;:'J r- ~ ". '. -