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Home My WebLink About94-02653 -- \\J ~ V) I I (I . t- 1 ;r ~;. t r -; -' .>' 01 I r<) l{)1 ...9 ". rJ.. t;. \ U I I 71 0- ....... ,. M. PAULETTE STEELE, Plaintiff . . IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO, 94- ~tC5J CIVIL TERM v. JEAN STEELE, Defendant : PROTECTION FROM ABUSE TEMPORARY PROTECTIVE ORDER AND NOW, this I~' day of May, 1994, upon presentation and consideration of the within Petition, and upon finding that the Plai~tiff, is in immediate and present danger of abuse from the Defendant Jean Steele, the following Temporary Order is entered: 1. The Defendant, Jean Steele, residing at 4 Pocono Drive, Mechanicsburg (Upper Allen Township), Cumberland County, Pennsylvania is hereby enjoined from abusing the Plaintiff, M. Paulette Steele or placing Plaintiff in fear of abuse. 2, The Defendant is enjoined from having any contact with the Plaintiff, including, but not limited to, the following: a) entering Plaintiff's home; b) entering Plaintiff's place of employment; c) stalking Plaintiff; or d) harassing Plaintiff, LAw omcle SNELBAKER Ilo BRENNEMAN This Temporary Order shall remain in effect until a final order is entered in this case. A hearing shall be held on this matter on the ~ day of ~, 1994, at J: 00 o'clock ~.M, in Courtroom No, ~, Cumberland County courthouse, Carlisle, Pennsylvania. The Cumberland County Sheriff's Office shall attempt to make service at the Plaintiff's request, but service may be accomplished under any applicable Rule of civil Procedure. The Upper AIIsn Township Police Department will be provided with a copy of this Order by attorneys for Plaintiff. This Order shall be enforced by any law enforcement agency when a violation occurs by arrest for indirect criminal contempt. The arrest may be 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 the Court is unavailable, the Defendant shall be arraigned before the appropriate district justice. BY THE COURT, /ilL J. LAW Ol"TlClI:8 SNELBAKER & BRENNEMAN -2- M. PAULETTE STEELE, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. : : NO. 94- CIVIL TERM JEAN STEELE, 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 within twenty (20) days 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 petitioner. 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 CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP, Court Administrator One Courthouse Square Carlisle, Pennsylvania 17013-3387 (717) 240-6285 SNELBAKER & BRENNEMAN, P. C. By: ~~ Attorney for PIa ntiffs M. PAULETTE STEELE, Plaintiff : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 94- CIVIL TERM JEAN STEELE, Defendant PROTECTION FROM ABUSE PETITION FOR PROTECTIVE ORDER UNDER THE PROTECTION FROM ABUSE ACT 23 PA. C.S. ~ 6101. et sea. ABUSE 1. The Plaintiff, M, Paulette Steele, is an adult individual whose address is 806 Grantham Road, Grantham (Upper Allen Township), Cumberland County, Pennsylvania 17027. 2. The Defendant, Jean Steele, is an adult individual whose address is 4 Pocono Drive, Mechanicsburg (Upper Allen Township), Cumberland County, Pennsylvania. 3. The Plaintiff is married to Kenneth D. Steele, although divorce proceedings were instituted in January of 1994. Kenneth D. Steele continues to reside at 806 Grantham Road, Grantham, Pennsylvania with Plaintiff and their four children: Dustin Tyler Steele, born 6/18/79 Tiffany Rae Steele, born 12/27/81 Matthew Joel Steele, born 7/27/83 Keegan David Steele, born 2/17/89 LAW OI'1"ICII:. SNELBAKER a BRENNEMAN 4. The Defendant, Jean Steele, is the mother of Kenneth D. Steele. 5. The Defendant, Jean Steele, is the mother-in-law of Plaintiff, M. Paulette Steele. 6. On Sunday, May 15, 1994, at Plaintiff's residence, the Defendant abused Plaintiff by attempting to cause, and intentionally, knowingly and recklessly causing bodily injury to Plaintiff in the following manner: Defendant stood on the first floor of the house at the bottom of the stairway leading from the second floor. Plaintiff walked down the stairway and tried to move past Defendant, Defendant did not move away to allow Plaintiff to easily pass by her. As Plaintiff squeezed against the wall in an effort to move past Defendant, Plaintiff mumbled "you bitch." Defendant grabbed Plaintiff and began punching her with closed fists. Plaintiff pushed Defendant away in an effort to avoid being punched again. Defendant came right back at Plaintiff and started punching again. Plaintiff tried to step backwards to avoid the punches. Plaintiff's husband then intervened by taking hold of Defendant, pulling Defendant away from Plaintiff and taking Defendant out the front door. LAW O,.'ICES SNELBAKER a BRENNEMAN 7, Defendant's punches caused Plaintiff substantial pain. -2- ........,~,~'" .0.<'_""""""- 8. On other occasions, Defendant harassed Plaintiff including, but not limited to the following: a. On or about December 28, 1993 at approximately 7:00 P.M., Plaintiff was driving her Subaru automobile, A light blue Crown Victoria driven by Defendant followed Plaintiff throughout the greater Harrisburg area including numerous lane changes and turns. Defendant followed Plaintiff for approximately 30 minutes. Plaintiff believes and therefore avers that Defendant followed her with the intent to harass, annoy or alarm Plaintiff. b. In or about the end of November, 1993, Plaintiff's automobile was followed by a light blue Crown Victoria automobile which Plaintiff believes and therefore avers was driven by Defendant in an effort to harass, annoy or alarm Plaintiff. 9. The Plaintiff believes and therefore avers that she is in immediate and present danger of abuse from the Defendant and that Plaintiff is in need of protection from such abuse. 10. The Plaintiff desires that the Defendant be ordered to refrain from having any contact with Plaintiff including, but not limited to, entering her home, entering her place of employment, stalking the Plaintiff or harassing the Plaintiff. B. COSTS AND ATTORNEYS' FEES 11. The Plaintiff asks that the Defendant be ordered to LAW O....ICU SNELDAKER It BRENNEMAN pay the costs of filing and service of this lawsuit and to pay reasonable attorneys' fees pursuant to the Protection From Abuse -3- f J ! Act. WHEREFORE, pursuant to the provisions of the Protection From Abuse Act, of October 7, 1976, 23 Pa.C.S. Sections 6101, ~ sea., as amended, the Plaintiff prays your Honorable Court to grant the following relief: A. Grant a Temporary Order: 1. Requiring the Defendant to refrain from abusing the Plaintiff or placing Plaintiff in fear of abuse. 2. Requiring the Defendant to refrain from having any contact with the Plaintiff including, but not limited to, restraining the Defendant from: a) entering Plaintiff's home; b) entering the Plaintiff's place of employment; c) stalking Plaintiff; and d) harassing Plaintiff. B. Schedule a hearing in accordance with the provisions of the protection From Abuse Act and, after said hearing, enter an order to be in effect for on year: 1. Requiring the Defendant to refrain from abusing the Plaintiff or placing Plaintiff in fear of abuse. 2, Requiring the Defendant to refrain from having any contact with the Plaintiff including, but not limited to, restraining the Defendant from: a) entering Plaintiff's home; b) entering the Plaintiff's place of employment; c) stalking Plaintiff; and d) harassing Plaintiff. 3. Ordering the Defendant to pay all costs of filing and service of this lawsuit and reasonable attorneys' fees. 4. Directing that a copy of this Petition and Order be delivered to the Upper Allen Township LAW OI"I"ICES SNELBAKER a BRENNEMAN -4- b police Department as the police department with jurisdiction to enforce this Order. 5. ordering such other relief as may be just and proper. Respectfully Submitted, SNELBAKER & BRENNEMAN, P. c. By: OODJJI~I/ ft Phil~' S;I~Esquire 44 W. Main street Mechanicsburg, PA 17055 (717) 697-8528 Attorneys for Plaintiff Date: May 18, 1994 LAW C,,.ICII SNELBAKER e. BRENNEMAN -5- . VERIFICATION I verify that the statements made in the foregoing Petition are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. 54904 relating to unsworn falsification to authorities. fl18u.-tt ;0~.5tu.).J M. Paulette steele Date: May 18, 1994 U.W O"ICU SNILBAKER a BRENNEMAN SHERIFF'S RETURN CG1MCJIIlWEALTH OF PENNSYLVANIA: COUNI'Y OF ClMBERLAND In The Court of Common Pleas of Cumberland County, Pennsylvania No. 94-2653 civil Term Temporary Protective Order Protection From Abuse Notice and Petition M. Paulette Steele VS Jean Steele Timothv Reitz , lUI6!llCilflfX<<JX Deputy Sheriff of Cl.lnberland County, Pennsylvania, who being duly sworn according to law, says, that he served the within Temoorarv Protective Order Protection From Abuse Notice and Petition , the defendant, at 5:06 o'clock upon JpAn Steele P .M,~ / EDST, on the , 19....2iat day of 18 May 4 Pocono Drive, Mechanicsburq . Cl.lnberland County, Pennsylvania. by handing to Jean Steele a true and attested copy of the Temporary Protective Order Protection FrO/O Abuse Notice and Petition and at the same tline directing her attention to the contents thereof and the "Notice to Plead" endorsed thereon. Sheriff's Costs: Docketing Service Affidavit Surcharge ?~~-4? 14.00 6.72 2.00 22.72 Pd. by Atty. 5-19-94 R. Thomas Kline, Sheriff by T~~ Deputy Sheri Sworn and subscribed to before me this J. 3.Ml day ofntll.<, . 19 {N A.D. ~IL"- () )1l<.(CL~, ~lf,,' Prothonotary . . .' M, PAULETTE STEELE, Plaintiff . . IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V, NO, 94-2653 CIVIL TERM JEAN STEELE, PROTECTION FROM ABUSE Defendant ORDER OF COURT AND NOW, to wit, this z. t. . day of (\-\0., 1994, upon presentation and consideration of the within Consent Agreement, the follOldng Order is entered: 1. The Defendant, Jean Steele, residing at 4 Pocono Drive, Mechanicsburg (Upper Allen Township), Cumberland County, Pennsylvania is hereby enjoined from abusing the Plaintiff, M. Paulette Steele or placing Plaintiff in fear of abuse. 2. with the following: The Defendant is enjoined from having any contact Plaintiff, including, but not limited to, the a, entering Plaintiff's home; b. entering Plaintiff's place of employment; c, stalking Plaintiff; or d, harassing Plaintiff. This Order shall remain in effect for a period of one year from the date of this Order. The Upper Allen Township Police Department will be provided with a copy of this Order by attorneys for Plaintiff. p~ din;!" ,:"''1:' ,'.I't Af,Y ,i '( H~y Z!j 2 2& PH '9~ (.l: 'A ..;~ ~ ~ ;'r l;~'.)'! . -:." !. 2, The Defendant is enjoined from having any contact with the Plaintiff, including, but not limited to, the following: a) entering Plaintiff's home; b) entering Plaintiff's place of employment; c) stalking Plaintiff; or d) harassing Plaintiff. WHEREFORE, the parties request that an Order of Court be entered to reflect the terms of this Consent Agreement. ~lC-tV~1xLtr M. Paulette Steele Plaintiff P~~ Esquire Attorney for Plaintiff Snelbaker & Brenneman, P.C. 44 West Main street Mechanicsburg, PA 17055 (717) 697-8528 ~....~ 3b~,,'\\.. Jean Steele Defen ant \, \ James G'. Attorney Hepfo~d, Swartz 111 Notth Front HarrisB,urg, PA (717) 234-4121 Esquire & M ~~an Street 171098-0889 '. CERTIFICATE OF SERVICE I, PAULINA PATTI THOMAS, on May 25, 1994 do hereby state that I have served a copy of the Consent Agreement Pursuant to Rule 1037 by depositing the same in the U,S, Mail, postage pre-paid, to the following address: Philip H, Spare, Esquire Snelbaker & Brenneman, P.C. 44 West Main Street Mechanicsburg, PA 17055 Respectfully submitted, HEPFORD, SWARTZ & MORGAN 'BY-C3,~~~ paulina Pat~t'Thomas Legal Secretary to James G. Morgan, Jr, 111 North Front Street Harrisburg, PA 17101-0889 (717) 234 -4121 Q ~~ ~~ ~~.~~ ~~~~ SUffi ~I~~ ~ .!~ ~ ;~ .~ ~~ I :i I . ~ > ~ ~ z ~ i S:. 2- ...: loW ,... N - -- ~ all Vi ... ~ :! ON" = ;;: ::J ii: .... ~ >>t : Ocr:u:,g~!:: ~<= .z:': j:l: ~ 0 '" '" CI] ~~ a.: c:. ;! o ~ g 5 a:: _ ~ Iol 0- :t- ... ;< ... - '" ~ ::a:: :I: I I . .. ." . . ... M. PAULETTE STEELEr Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 94-2653 CIVIL TERM v. . . . . JEAN STEELE, Defendant . . PROTECTION FROM ABUSE . . . . PRAECIPE TO THE PROTHONOTARY: Please withdraw the appearance of Snelbaker & Brenneman, P. C. by Philip H. spare, Esquire for the plaintiff in the above- captioned action and enter the appearance of Ricci and Taneff by Paul Taneff, Esquire for the Plaintiff. SNELBAKER & BRENNEMAN, P. C. .,... By: p~~~SqUire 44 W. Main Street Mechanicsburg, PA 17055 (717) 697-8528 Withdrawing Attorney for Plaintiff M. Paulette Steele Date: August 16, 1994 RICCI & TANEFF By: Taneff, Esqu 4219 Derry Street Harrisburg, PA 17111 (717) 564-5833 Appearing Attorney for plaintiff M, Paulette Steele LAW O,.,ICES SNELDAKER a BRENNEMAN Date: V - /J/- '1-1