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HomeMy WebLinkAbout94-02850 .n e \.9 VI I/) o ~ (0 ~ ) , / ~/ I (1 '-I j\J ! _I I _! ANN MARIE REED GROSS, Plaintiff v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 94-2850 CIVIL TERM ANTHONY J. GROSS, Defendant PROTECTION FROM ABUSE TEMPORARY PROTECTIVE ORDER AND NOW, this .,J day of I ".'1(" , 1994, upon presentation and consideration of the within Petition, and upon finding that Petitioner, ANN MARIE REED GROSS, is in immediate and present danger of abuse from the Respondent, ANTHONY J. GROSS, the following Temporary Order is entered. Respondent, ANTHONY J. GROSS, now residing at 2413 Logan Street, Harrisburg, Dauphin County, Pennsylvania 17110, is hereby enjoined from physically abusing Petitioner or otherwise placing her in fear of abuse and is ordered to stay away from the premises at 408 Orchard Lane, Mechanicsburg, Cumberland County, Pennsylvania. 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 ~n.day of j"l(,)tr , 1994, at/o'(!(1,4.M. in Courtroom No. ~ , Cumberland County Court House, Carlisle, Pennsylvania. Service of a certified copy of the Petition and this Order may be provided by the Cumberland County Sheriff's Office. SAlOIS, GUIOO, SIIUI'F & The Mechanicsburg, Upper Allen Township and lIarrlsburg MASLANU 2hWIli~hS"c" Police Departments wi 11 be provided with a copy of this Order Cwlidl',I'A 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 SAIDIS, GUIDO, SnUFF & MAS LAND 26 W, IIISh Sired Carll.I.,I'A ANN MARIE REED GROSS, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 94-2850 Civil Term v. ANTHONY J. GROSS, Defendant PROTECTION FROM ABUSE PETITION FOR PROTECTIVE ORDER RELIEF UNDER THE PROTECTION FROM ABUSE ACT 23 PS 5 6101 1. The Plaintiff is Ann Marie Reed Gross, an adult individual who currently resides at 408 Orchard Lane, Mechanicsburg, Cumberland County, Pennsylvania 17055. 2. The Defendant is Anthony J. Gross, an adult individual who currently resides at 2413 Logan Street, Harrisburg, Dauphin County, Pennsylvania 17110. 3. The Defendant is Plaintiff's spouse. 4. The Plaintiff filed for divorce on May 26, 1994. 5. In or about late April, 1994, the Defendant attempted to cause and intentionally, knowingly, or recklessly cause bodily injury to the Plaintiff, and by physical menace has placed the Plaintiff in fear of immediate serious bodily injury. This has included but is not limited to the following specific instances of abuse: A. On or about May 1, 1994, the Defendant forced Plaintiff to remain in the basement of Defendant's residence (formally the marital residence of the parties) while Plaintiff rewashed and dried Defendant's laundry. B. On or about May 4, 1994, upon returning from his employment, Defendant accosted and yelled at Plaintiff, then SAIDIS, GUIDO, SnUFF & MASI,AND 26 W. IIISh Slrecl Carlhlc,l'A 1\ I II I I ! Defendant threw various potted plants at Plaintiff. C. On or about May 5, 1994, Defendant again accosted and yelled at Plaintiff, and thereafter threw various items at Plaintiff including various bottles of nail polish. D. On or about May B, 1994 (Mother's Day), upon Plaintiff's return from visiting her children from a previous marriage, I I I Defendant violently attacked Plaintiff throwing Plaintiff against the wall, and throwing various items, including a mattress at Plaintiff. Thereafter, Defendant forced Plaintiff to remain awake and look at Defendant from approximately ll:30 p.m. to 3:00 a.m. the next morning. E. On or about May 16, 1994, without any provocation, Defendant attacked Plaintiff and proceeded to rip Plaintiff's fingernails from her body. Thereafter, Defendant forcibly held Plaintiff while Defendant forcibly cut Plaintiff's nails and fingers. Thereafter, Defendant forced Plaintiff to sleep in Defendant's bedroom. I II be in 6 ~mmediate and present danger of abuse from Defendant, and !i 'I n ;, The Plaintiff believes and therefore avers that she will that she is in need of protection from such abuse. j; 7. The Plaintiff desires that Defendant be restrained from .1 ii 11 entering her place of employment, having any contact with her, or , from harassing her or her relatives. WHEREFORE, pursuant to the provisions of the Protection from Abuse Act of October 7, 1976, 23 PS 6101, et seq., as amended, the Plaintiff prays Your Honorable Court to grant the following relief: SAIDIS, GUJJ)O, SnUFF & MAS LAND 26W,IIIshSlItCI Carlhl"I'A II I. I . I, il II II II I , a. Grant a temporary order pursuant to the Protection from Abuse Act: 1. Requiring the Defendant to refrain from Rbusing Plaintiff or placing her 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 entering the place of employment of the Plaintiff and from harassing her or her relatives. 3. Ordering the Defendant to stay away from any residence the Plaintiff may in the future establish for herself . b. Scheduling 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 (1) year: 1. Requiring the Defendant to refrain from abusing the Plaintiff or placing her in fp.ar of abuse. 2. Requiring the Defendant to refrain from having any contact with the Plaintiff, including but not limited to, restraining the Defendant from entering the place of employment of the Plaintiff or from harassing her or her relatives. 3. Ordering the Defendant to stay away from the residence of Plaintiff the Plaintiff may in the future establish for herself. c. 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