HomeMy WebLinkAbout94-02708
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MARY L, GRUBB,
IN l1lE COURT OF ca.M>N PLEAS OF
CUMIlEIU.AND COlJI'(I'Y, PENNSYLVANIA
NO. 94- ) 'Iv ~J CIVIL TERM
Plaintiff
v.
JAY A, LOVE,
Defendant
I'R01'f,CTION fROM ABUSE
~~
AND NOW, this .2.iJt'A day of MIlY, 1994, upon presentation and consideration
of the within Petition, and upon flndlnK that the plaintiff, Mary L. Grubb, now
residing at 384 Helsen Lllne, cllrllsle, CUmberland County, Pennsylvania, is in
immediate and present danKer of IIbuse from the defendant, Jay A, Love, the
following Temporary Order Is entered.
The defendant, Jay A. Love, now residing at The Holly Inn, Mt. Holly
Springs, CUmberland County, Pennsylvania, Is hereby enjoined from physically
abusing the plaintiff, Mary L. Grubb, or placing her in fear of abuse.
The defendant is ordered to stay away from the plaintiff's residence
located at 384 lIelsers Lane, Carl Isle, cumberland County, Pennsylvania, a
residence which Is owned solely by the plaintiff.
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 exceed
$1,000.00 and/or by a sentence of up to six months in jail and any other
appropriate punishment.
The defendant is ordered to refrain from having any direct or indirect
contact with the plaintiff including, but not limited to, telephone and written
cOlllllunlcations.
The defendant is enjoined from harassing and stalking the plaintiff.
The defendant is enjoined from entering the plaintiff's place of business.
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This Order shall remain in effect until a final order is entered in this
case, A hearing shall be held on this matter on the ;l/,-cA day of May. 1994, at
::? :,3() ,1 .m.. in Courtroom NO.~. CUmberland County Courthouse. carlisle,
f
PeMsylvania.
The plaintiff may proceed in f2IIA oauoeris pending 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 Silver Spring Township Police
Department wi II be provided wi th cert ified copies of this Order by the
plaintiff'S 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 P.S. 6 6113).
By the Court,
t<r /I ;l
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/
Judge
MARY L. GRUBB.
IN TIlE COURT OF COMMON PLEAS OF
Plaintiff
v.
CUMBERLAND COUNTY. PENNSYLVANIA
NO, 94- .J 70P CIVIL TERM
JAY A. LOVE.
Defendant
PROTECTION PROM ABUSE
PETITION FOR PROl'ECl'I ON ORI>I';R
RELIEF UNDER TIlE PROl'ECl'ION PRaoI ABUSE
ACT, 23 P.S. ! 6101 et seq.
A. ABUSE
1, The plaintiff is an adult individual whose permanent address is 384
Heisers Lane, Carlisle, CUmberland County, Pennsylvania. 17013.
2, The defendant is an adult individual residing at The Holly Inn, Nt.
Holly Springs, CUmberland County, Pennsylvania. 17065.
3. The defendant has had an intimate relationship with the plaintiff,
4, Since approximately Nay 25. 1993, the defendant has attempted to
cause and has intentionally, knowingly, or recklessly caused bodily injury to the
plaintiff and by physical menace has placed the plaintiff in fear of imminent
serious bodily injury. This has included but is not limited to the following
specific instances of abuse:
a. On or about May IS, 1994. at approximately 3:00 a,m, the
defendant drove around the plaint iff's driveway at a high
speed, telephoned her minutes later using foul language and
making vulgar remarks, then Shortly afterward came to her home
and pounded on her door demanding entry. When the plaintiff
refused to let the defendant in. he punched his fist through
the glass on the door. kicked the door causing the door jamb
and lock to break, and forced the door open. Fearing for her
safety and that of her 5 year-old grandson, the plaintiff
called 911, The defendant screamed and yelled in the
background as the plaintiff, who had closed herself in the
bathroom, spoke on the portable telephone with the
Pennsylvania State Police, The defendant left the plaintiff's
home when he realized that the police were en route, The
defendant later telephoned the plaintiff while the police were
at her home and was warned by the State Trooper to leave the
plaintiff alone. The defendant called the plaintiff again
after the police left, threatening that he had a gun and would
use It on her and the police If anyone tried to pick him up.
The plaintiff reported the threats to the police iaaediately.
Later the same morning the defendant approached the plaintiff
at her booth at the Silver Spring Flea Market and demanded to
know if she had reported his threat to use the gun to the
police, The plaintiff told him she had and he swore at her
and left,
b, On or about May 25, 1993, the defendant punched the plaintiff
with his fist repeatedly about her head, face, arms and hands,
and pulled her hair as she drove her car causing her to slam
on the brakes to avoid losing control of the vehicle. The
plaintiff sustained bruising and swelling on the right side of
her face and head, bruising on her arms and hands, soreness
about her head and intermittent headaches for approximately 2
weeks as a result of this incident. The plaintiff sought
legal assistance from Legal Services, Inc. and a warning
letter was sent to the defendant. See attached Exhibit B,
which is incorporated herein by reference,
S, The plaintiff believes and therefore avers that she is in immediate
and present danger of abuse from the defendant and that she is in need of
protection from such abuse.
6. The plaintiff desires that the defendant be prohibited from having
any direct or indirect contact with the plaintiff Including, but not limited to,
telephone and written communications.
7, The plaintiff desires that the defendant be enjoined from harassing
and stalking the plaintiff,
8. The plaintiff desires that the defendant be restrained from entering
her place of employment,
B. EXCLUSIVE POS!~F.ssI~
9. The mobile home from which the plaintiff is asking the Court to
exclude the defendant is owned in the name of Mary L. Grubb, and the defendant
has never resided there,
C. LOSSES
The plaintiff has suffered losses as a result of the abuse by the
The losses are listed on Exhibit A attached and incorporated by
10.
defendant.
reference,
11. The plaintiff asks for attorney's fees for Legal Services, Inc., and
filing and service fees of this lawsuit pursuant to the Protection from Abuse
Act.
D, STA'lUS TO PIlnr'F.P.Il IN FORMA PAUPERIS
12. The plaintiff is self-employed at the Silver Spring Flea Market and
earn approximately $100 weekly.
13, 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 frOll Abuse Act"
of October 7, 1976, 23 P,S. 9 6101 ~ 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 frOll abusing the
plaintiff or placing her in fear of abuse;
2. Ordering the defendant to refrain from having any direct
or indirect contact with the plaintiff including, but not
limited to, telephone and written communications;
3. Ordering the defendant to refrain from harassing and
stalking the plaintiff;
4. Prohibiting the defendant from entering the plaintiff's
place of employment;
S. Ordering the defendant to stay away from the residence
located at 384 Heisers Lane, Carlisle, CUmberland County,
Pennsylvania, which the parties have never shared, and
6, Ordering the defendant to stay away from any residence
the plaintiff may in the future establish for herself,
8, 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 or placing her in fear of abuse,
2. Ordering the defendant to refrain from having any direct
or indirect contact with the plaintiff including, but not
limited to, telephone and written communications.
3, Ordering the defendant to refrain from harassing and
stalking the plaintiff.
4. Prohibiting the defendant from entering the plaintiff's
place of employment.
S. Ordering the defendant to stay away from the residence
located at 384 Heisers Lane, Carlisle, CUmberland County,
Pennsylvania, which the parties 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 reimburse the plaintiff's out-
of-pocket losses suffered as a result of the abuse including
but not limited to the losses listed on the attached sheet
marked Exhibit A.
8, Ordering the defendant to pay all costs of filing and
service of this lawsuit and attorney's fees to Legal Services,
Inc.
The plaintiff further asks that this Petition be filed and served without
payment of costs, pending a further order at the hearing, and that certified
The above-named plaint iff. Mary L. Grubb. verifies that the statements lIlIde
in the above Petition are true and correct. The plaintiff understands that false
statements herein are l118de subject to the penalties of 18 Pa. C,S, g 4904
relating to unsworn falsification to authorities.
Date: n',(), /'1, /99</
/J1 C1rir ,-Y lh~u-
Mary L rubb, Plaintiff
.MARY L. GRUBB,
IN THE COURT OF cor.M>N PLEAS OF
Plaintiff
CUMBERLAND COUI'n'Y, PENNSYLVANIA
v,
NO, 94-
CIVIL TERM
JAY A, LOVE.
Defendant
PROTECl'ION FROM ABUSE
our-oF-FOaCET LOSSES
The plaintiff requests that the defendant reimburse her out-of-pocket
losses, including but not limited to the following:
Repair and replacement of door, jamb and lock
(Estimates not available at the time of filing petition)
$
Exhibit A
~
LEGAL SERVICES, INC.
8 Irvine Row
Carlisle. Pennsylvania 17013
(717) 243.9400
Fax (717) 243-8026
West Shore (717) 766-8475
FrukUD FInIS ......
CWDbcnbufl.Pc~ 17201
(111)_'114
19 W. lup 51tMt
OcO_r.__ tnU
(7I1)1l4-1m
June 3. 1993
103 Unc:altI Way EaII
r,o. 801445
McOJMdbbu.... PtlUllJlnnil 1m]
(111)......"
Jay Love
Valley Motel Room 12
1580 Ritner Highway
Carlisle, PA 17013
Dear Mr. Love:
Mary Grubb recently came to our office to discuss incidents in
which she says you physically abused her, She has been advised of
the criminal and civil remedies available to her.
You should be aware that the criminal laws apply to acts of
violence even when they occur between boyfriend and girlfriend,
The penalty for simple assault, which can include "attempts by
physical menace to put another in fear of imminent serious bodily
injury" is up to two years imprisonment and a $5000.00 fine, For
harassment (including striking, shoving, kicking, alarming or
seriously annoying a person), the punishment is up to a $300.00
fine and 90 days imprisonment, Harassment by communication is also
a crime punishable by up to one year in prison or a $2500,00 fine.
Ms. Grubb has also been advised of a civil remedy available
under the Protection from Abuse Act, Under this Act, she can
petition the court to issue a Protective Order, If such an order
is entered, it will be placed on file with the police, and if you
violate the order, YOII will be taken before the judge who issued
the order. The judge will then decide what punishment is
appropriate. A person who violates such an order can be imprisoned
for up to six months,
Ms. Grubb also described incidents in which you have come to
her home uninvited. This letter is to inform you that you are not
to go to her residence again. Furthermore, this letter officially
gives you notice that you will be considered a defiant trespasser
if you come to her residence. The penalty for defiant trespass is
up to one year imprisonment.
Ms. Grubb does not wish to pursue legal remedies against you
at this time, but she does want you to be aware that if there is
further violence or threats of violence toward her or if you
attempt to enter her residence, she is prepared to take legal
action.
c;.X'flfg,r B
SERVING ADAMS. CUMBERLAND. FRANKLIN AND FULTON COUNTIES
.
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I hope your awareness of the consequences of violent acts and
any illegal actions mentioned in this letter will help prevent the
recurrence of such acts in the future, I would also like you to be
aware that there are counselors in the area who specialize in
helping people who wish to eliminate violence from their close
relationships. The fees for some counsellors are based on the
income of the person requesting the service. In the Carlisle area,
Stevens Mental Health Center has sliding scale fees, and in the
West Shore area, Holy Spirit has such fees, I strongly recommend
these or other counselling services,
Sincerely,
LEGAL SERVICES, INC.
~ /(J-
;yt'-tl-...., ~d/u- '-1
~~an Carey ~
Attorney at Law
JC:lc
cc: Mary Grubb
State Police
Carlisle Borough Police
~
MARY L. GRUBB.
IN TIlE COURT OF COMMON PLEAS OF
Plaintiff
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 94-2708 CIVIL TERM
PROTECTION FROM ABUSE
v.
JAY A, LOVE.
Defendant
PROTECTION ORDER
AND NOW, this .ff. day of May, 1994, upon consideration of the Consent
Agreement of the parties. the following Order is entered:
1. The defendant. Jay A. Love, is enjoined from physically abusing the
plaintiff. Mary L, Grubb. or from pla~ing her in fear of abuse,
2. The defendant is enjoined from having any direct or indirect contact
with the plaintiff including, but not limited to. telephone and written
communications.
3. The defendant is ordered to refrain from harassing and stalking the
plaint iff.
4, The defendant is prohibited from entering the plaintiff's place of
business.
5. The defendant is ordered to stay away from the residence located at
384 Heisers Lane. Carlisle. Cumberland County, Pennsylvania. which the parties
have never shared.
6. The defendant is ordered to stay away from any residence the
plaintiff may in the future establish for herself.
7. The defendant is ordered to reimburse the plaintiff's out-of-pocket
losses suffered as a result of the incident on or about May IS, 1994. including
but not limited to the loss~.s' listed on Exhibi t A. The defendant shall reimburse
the total amount of the losses ($150,00)
h~ \:" 21 G Z
entry of the Protect ion oHlh.'
to the plaintiff within 30 days of the
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8. This Order shall remain in effect for a period of one year.
9, The Pennsylvania State Police and the silver Spring Township Police
Department shall be provided with certified copies of this Order by the
plaintiff's attorney and may enforce this Order 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 P.S. ft 6113).
By the Court,
,//Ji
-
MARY L, GRUBB.
IN THE COURT OF COMMON PLEAS OF
Plaint iff
CUMBERLAND COUNTY. PENNSYLVANIA
v.
NO, 94-2708 CIVIL TERM
JAY A. LOVE.
Defendant
PROTECTION FROM ABUSE
CONSENl' /tORE6llfNI'
This Agreement is entered on this ~3 o:!l. day of May. 1994, by the
plaintiff. Mary L. Grubb, and the defendant. Jay A, Love, The plaintiff is
represented by Joan Carey of LEGAL SERVICES. INC.; the defendant is unrepresented
but is aware of his right to have an at torney, The part ies agree that the
following may be entered as an Order of Court.
1. The defendant. Jay A. Love. agrees to refrain from abusing the
plaintiff. Mary L. Grubb. or placing her in fear of abuse,
2. The defendant agrees not to have any direct or indirect contact with
the plaintiff including. but not limited to. telephone and written
communications.
3, The defendant agrees not to enter the plaintiff's place of business,
4. The defendant agrees not to harass and stalk the plaintiff.
5, The defendant agrees to stay away from the plaintiff's residence
located at 384 Heisers Lane. Carl isle, Cumberland County, Pennsylvania. which the
parties have never shared.
6, The defendant agrees to stay away from any residence the plaintiff
may in the future establish for herself,
7. The defendant agrees to reimburse the plaint iff's out-of-pocket
losses of $150.00 suffered as a result of the incident on or about May 15. 1994.
including but not limited to the losses listed on Exhibit A. Defendant agrees
-
to reimburse the total amount of the losses to the plaintiff within 30 days of
the entry of the Protection Order,
8. The defendant. although entering into this Agreement I does not admi t
the allegations made in the Petition.
9. The defendant understands that the Protective Order entered in this
matter shall be in effect for a period of one year.
10. The defendant understands that this Order shall be enforceable in the
same manner as the COurt's prior Temporary Protection Order entered in this case,
WHEREFORE, the parties request that a Protection Order be entered to
reflect the above terms.
-~ Ti4.~.ft
~ A, ve, Defendant
LEnAL SERVICES, INC.
8 Irvine Row
Carlisle, PA 17013
(717) 243-9400
. MARY L. GRUBB.
IN TIlE COURT OF COMMON PLEAS OF
Plaintiff
CUMBERLAND COum'Y, PENNSYLVANIA
v.
NO, 94-
CIVIL TERM
JAY A, LOVE,
Defendant
PROTECTION FROM ABUSE
our-oP-POCKET LOSSES
The plaintiff requests that the defendant reimburse her out-of-pocket
losses, including but not limited to the following:
Repair and replacement of dOllr. jamb and lock
Labor
$100,00
50.00
$150.00
Exhibit A
SHERIFF'S RETURN
CCl'M)NWEALTH OF PENNSYLVANIA,
COUNl'Y OF CLfolBERLAND
In The Court of Common Pleas of
Cumberland County, Pennsylvnaia
No. 94-2708 Civil Term
Temporary Protective Order
Protection From Abuse, Notice and
petition for Protective Order
Mary L. Grubb
VS
Jay A. Love
"";mnt-hy Rpit"7.
. ~K~ Deputy Sheriff of
Cunberland County, Pennsylvania, who being duly sworn according to law, says,
that he served
the within Temoorarv Protective Order Protection From Abuse,
Notice and Petition for Protect1ve uraer
r.nVF> , the defendant, at 3:40 o'clock
upon 1::.y A
P .M. ~8~ I EDST, on the
20
May
day of
, 1994 at
The Holly Inn, 31 S. Baltimore Ave., Mt. Holly Spring~rlandCounty,
Pennsylvania. by handing to Jay A. Love
a true and attested copy of the Temporary Protective Order Protection Fr9m
ADuse, Not1ce & ~et1t1on tor ~rOteCt1ve urder
and at the same time directing his attention to the contents thereof and
the "Notice to Plead" endorsed thereon.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
So answers:
14.00
3.92
17.92
r~:' ,,<~~
R. Thanas Kline, Sheriff
by
Sworn and subscribed to before me
a...
a r - day of Ill,!
Deput
this
19 11 A.D.
9r,. C. )11.. ic,. '. ~
Prothonotary
,
MARY L. GRUBB,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V.
JAY A, LOVE,
94-2708 CIVIL
CHARGE: INDIRECT CRIMINAL CONTEMPT
Defendant
ORDER OF COURT
AND NOW, this ~ day of December, 1994 in consideration of
the attached Commonwealth's Petition, the defendant, JAY A. LOVE,
is directed to appear before the Court on the,"uII,-( day of
ID~/Jllli~J , 1994 at /11: 30 o'clock ~.m. in Courtroom * 1- of
the Cumberland County Courthouse, Carlisle, Pennsylvania, to show
cause why the defendant should not be adjudicated in indirect
criminal contempt of Court.
Defendant has a right to be represented by an attorney. If
defendant cannot afford an attorney, one will be assigned to
repcesent the defendant. Further, if defendant fails to appear
an arrest warrant will be issued,
By the Court,
. Aiel
Hess
J.
Thomas A. Placey
Assistant District Attorney
Jay A. Love, Defendant
Office of The Public Defender
. .
MARY L. GRUBB,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V.
94-2708 CIVIL
JAY A, LOVE,
Defendant
CHARGE: INDIRECT CRIMINAL CONTEMPT
COMMONWEALTH'S PETITION FOR A HEARING ON CHARGES
OF INDIRECT CRIMINAL CONTEMPT
Thomas A. Placey, Assistant District Attorney of Cumberland
County, pennsylvania, files the following petition for a hearing on
charges of indirect criminal contempt against JAY A. LOVE, as follows:
1, A Protection From Abuse Order was entered by the Honorable
Kevin A. Hess on May 31, 1994, A certified copy of the Court Order is
attached as Exhibit 1,
2, Defendant's violation of this Order is averred in the
attached criminal complaint. Attached as Exhibit 2.
3, The police, upon contact by the victim, ascertained her
immediate safety, and were not able to locate the defendant in the
vicinity,
4. The victim has requested the filing of charges on indirect
criminal contempt.
5, The Commonwealth is requesting a hearing on the charges of
indirect criminal contempt pursuant to 23 Pa,C.S.A. Section 6113.
WHEREFORE, the Commonwealth requests a hearing on the charge of
indirect criminal contempt of the Protection From Abuse Order.
submitted,
Attorney
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MARY L, GRUDD.
IN THE COURT OF COMMON PLEAS OF
Plaintiff
v,
CUMBERLAND COUNT\'. PENNSYLVANIA
NO. 94-2708 CIVIL TERM
JAY A. LOVE,
Defendant
PROTECTION FROM ABUSE
PROTECfION ORDER
AND NOW. this .11 J! day of May, 1994, upon consideration of the Consent
Agreement of the parties, the following Order is entered:
1. The defendant, Jay A. Love, is enjoined from physically abusing the
plaintiff. Mary L. Grubb, or from placing her in fear of abuse.
2. The defendant is enjoined from having any direct or indirect contact
with the plaintiff including, but not limited to, telephone and written
communications.
3. The defendant is ordered to refrain from harassing and stalking the
plaintiff,
4, The defendant is prohibited from entering the plaintiff's place of
business.
5. The defendant is ordered to stay away from the residence located at
384 Heisers Lane, Carlisle, Cumberland County, Pennsylvania. which the parties
have never shared.
6. The defendant is ordered to stay away from any residence the
plaintiff may in the future establish for herself.
7. The defendant is ordered to reimburse the plaintiff's out-of-pocket
losses suffered as a result of the incident on or about May IS, 1994, including
,
l'
but not 1 imited to the losses 1 isted on Exhlbi t A, The defendant shall reimburse
the total amount of the
losses ($150.00)
r -,
oPbb~.' :: ~ l) :,
to the plaintiff within 30 days of the
ur-f
entry of the Protection
EXHIBIT 1
8. This Order shall remain in effect for a period of one year.
9. The Pennsylvania State Police and the Silver Spring Township Police
Department shall be provided with certified copies of this Order by the
plaintiff's attorney and may enforce this Order 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 P.S, 6 6113),
By the Court I
'/lJi
TRUE COpy FROM RECORD
In TftlImony WMreof. I here unto Sc.1 my hind
and I~ 01 saifJ CoIiri ill CtlrUs6e Pa
This day of Du.!., . 19 C(~
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ProChonocary I
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CRIMINAL COMPLAINT (POLICE)
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TYP.
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YEAR
COMPLAINT NUMBER
Compl.lnt Numb." if Other P.rtic:ip.nll
DISTRICT JUSTICE
MAGISTERIAL DISTRICT NO.
INCIOENT NUMBER UCR NO. OTN
H2-799161 999
I,
T['>:' Rnn"ln 'I' T,F.TnTr.:~
("'tAm~ nf Affll1l1tJ
COMMONWEALTH OF PENNSYLVANIA
DEFENDANT VS.
NAME r-
AND Jay A. LOVE
ADDRESS 1470 York Rd.
carlisle, Pa. 17013
of pa ~~~~o Pnl;ror ~A~';Q'O. on
(ldtl1ti{Y drpfJr,mtl11 0" 1111'11(')' rtprtltfUtd rind potltln~1 whdh'is;oI1J
RSA
AKA
1lOB:09-05-54
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do hereby state:
(1) Iia 1 accuse the above named defendant. who lives at the address set forth above or.
. 0 I accuse an individual whose name is unknown to me hut who is descrihed as
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(2)
o his nickname or popular designation is unknown to me and. therefoTl'. I have designated him herein as John Doe;
with violating the penal laws of the Commonwealth of Pennsylvania at Sr 11/15, Sr 74, Srl74 and Sr34
Monroe Twp. and SOuth Middleton Twp. II'loll 1'-1'..11I11,,1 Suhd,,,,,,,u'l
in CuIrberland County on or ahout ll/?Cl/Cld "I- <>rr""w 71'130 h",,,,.
Participants were "I tllt'ri' Mo"'" fhJ"'K'Plllll1. pl"'ll' 0'1'" ".HlIt" 1I,.,f', '1'111'""m~ tI,,. ""","..f olf"'H' tlt'Jt'tld..mt,
Jay A. LOVE
The acts committed by the accused were:C~ INDIRECT CRIMINAL ATI'EMPT:
In that the defendant did violate Cumberland County Judge Kevin HESS's Protection
from Abuse Order # 94-2708 issued by said judge on 05/31/94 pursuant to the
provisions of the Protection From Abuse Act, 23 Pa CS 6101-6117, as amended.
AFFIDAVIT OF PROBABLE CAUSE: On 11/29/94, victim had been at the Haar's auction in
York county at approx. 2030 hrs. While there, she observed the def. He began walking towards
her. She quickly went to her vehicle and left the area. She observed the def. pull his
white in color 1986 Buick Sommerset vehicle behind her vehicle as she was leaving. He
continued to follow her from Sr 11/15 to Sr 74 to Sr 174, to Sr 34. This action
greatly upset and alarmed the victim, and also violated the e ORDER. Def. is
prohibited from harassing and stalking the victim, placing her in fear of abuse, and
from having any direct or indirect contact with her. Victim- Mary Louise GRUBB, 384 Heisers
Lane, Carlisle, Pa. 17013, WjN-F-SO.
all of which were against the peace and dignIty of the Commonwealth of Pennsylvania and contrary to the Act of Assembly,
or in violation of and of the Act of
,Sl'f"t'""/ (S"h.sntl"'"
or the
Ordinance of
II'(JI'''CoIl.\lIh.dllfJIO''J
(3) I ask that a warrant of arrest or a summons be issued and that the accused be requirl:d to answer the charges
I have made.
(4)
I. verify that the facts set forth in this complaint are true and correct to the best of my knowledge or infor-
mation and belief. This verification is made subject to the penalties of Section 4904 of the Crimes Code
(18 Pa. C.S. 84904) relating to unsworn falsification to authorities.
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(SiRnolu,", or Affiant)
.1/()V~/"1/'.~ . 19 '/ 'I
AND NOW. on this .19 . I certify the complaint has been properly completed and
verified, and that there is probable cause for the issuance of process.
(SEAL)
(Malli,trriallJistrirt)
(/B&uinR Authu"t)"
AOPC 411,a6,po
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