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Home My WebLink About94-03306 VI, IN THE COUR1 01' COMMON PLEA6 OF CUMBERLAND COUN1Y, PENNSYLVANIA NO. \J 4 - 3'~ () r, C I V I L TE RM PROTEC110N FROM ABUSE PAULA BROWN, p101nt; ff IWBEH1 YENFEA, De fendanl NOl ICE You have bun sued In court. If you wuh to defend a9111nst the Cl11101S 5"t folth ln the following pOlles, you must take octlon prompt ly oltel tillS Pllt 1110n, Order IIlId Not ice are served, by appearing pel~onal ly 01 by attorney ot the hoorlng scheduled by tile Coult onli J,lIUlillllt lny 10 tho Court your dufens!!s or object 10ns to Ihe clalm~ !llll forth agaln51 you. You ore warned Ihot If you fall to lfo so tile Coull may pr,]CI1IHt wlthoul you. and 8 Judgment IIIlIy be ontllllllf 11111111151 you by thl! Coull wllhoul fUlthur notlcll fot Ilny monoy clUlInlld In IhlJ Pol It Ion 0' fOI /lny olher cllllm or 11!llef Illlluobtfl(j by Ihe pl'l1l1l1ff, IOU mil) 10tillIT'OnllY or IHOlllltly 01 ollwl tlllhl5 ""portanl to you, yOU BI10UUI'A~f 11111; PAPUi I.' IOUIl LAWrlH A1 ONCE. IF YOU DO N01 HAVE A lAWYER all CANNOT AI FOIlO otH. GU TO OR 1ELEPHONE THE Off ICI fiEl rOIHH IlJ:LuW 10 I INlJ OUT WHIRl-IOU CAN GEl LEGAL HELP, coun 1 ADM I Nib IliA 1011, 4 t h 110011 CUMIlFHI Aim COUNT\' COUHlltOLJSL CAIlLlbU., PINNbYIVANIA 1701,) IIIIPHUNI tWMIHIl: (717) 240b20l) threlltened her 61l>' 1119 , "If I lellve, you won't be around." The plaintiff feared for her Bllfety Blnce she Interpreted this llB a threat to her life. b, On or about June 13, 1994, the defendant burst into the plaintlff's bedroom lit 1 :00 a,lO., screamed lit her, grabbed her by the shoulders and shook her forcefully, and pushed her. c. On or about April 8, 1994, while the plaintlff was lying In bed, the defendant took botll of his flsts and punched the bed beside both sides of her head several limes, cllusin9 the plaint'ff to felll for het safety, In 6n effort to protect herself, the plaintlff rolled Into a fetal Posit,on, and the defendant punched the plalntlff about the head and ear, causing sllvere bruiSIng, redness, and swell iny. d. On or ahout APril 13, 19U4, the defendllnt \ltabbed the plaint iff IInd ShOVIlI! her several t ,mes. The defendant then pushe,! the plaint1ff wlth enouyh torce tu cause het to fall backward a Ill! h1l the back of her Iwad against tht! (offee table, caUSing palll find blulsing, 1I1e defendant also ,trew hls f,sl back a8 if to punch the p1;!intiff suveral tllnes, causing lIer to fear. II. Slncs Apll1 1994, ths 11uf'lIldllnt has abuslllt thll plaintiff IIpplo,lmately ..vllry otl1l1l Wlllj~ 11i WIlYS IllclUlJlng, but Ilot limited to the fol1uwillg: 11IHtl1tlY, slapPlllg, lh(J~jng, Alld fmeilHl !tHl plaintIff to hllVIl ~tH. 5. 1l1e pllllllt"f heljilvefJ lilli' tharufolllavefl! thllt she WIll Ile In ;lfllntldll1llt 11 t lit IJlBSIlIlI llangel 01 abl/be flOIll tllll dllfllllltollf bllOllll, bhl< IIlIIIIIIII HI !tIll hUlna WlttllllJl tllll dHfulldOl1t 'I, exclusion, and that she is in need of protection from such abuse. 6. The plaintiff desires that the defendant be restrained from entering her place of employment, having any contact with her, harassing or stalking the plaIntiff, and from harassing the plaintiff's relatiVes, B, EXCLUSIVE POGS~SSION 7. The home from which the plaint iff is asking the Court to exclude the de f end ant is owned in t he names of PAULA BROWN and DEBORAH ALBERT, C. LOSSES AND ATTORNEY FEES 8. The plaintiff asl<s to be reimbursed for fi li n9 fees and service costs pursuant to the Protection From Abuse Act. 9, The plaint1ff asks for attorney fees to be patd to Legal Services, Inc. pursuant to the Protoct ion from Abuse Act. WHEREFORE, pursuant to the provisions of the "Protection from Abuse Act" of October 7, 1976, 23 P.S. Sect ion 6101 et SI1Q., as amended, the plaint 1ff prays this Honorable Court to grant the follOWing reltef: A, Grant II Temporary Order pursuant to the "Protect Ion from Abuse Act:" 1, ReqUiring the defendant to refrain from abusing the plaintiff or placing her In fear of abuse, 2. RequHtng the dufendant to rei rain from havin9 any contact with the plaIntiff, Including, but not limited to, restraining the defendant 11'0111 entering the plalnt1ff's place of 1l11l1l1()YlIlllnt, from hllrasslng or stalking the plaintiff, and flom hll/86llng the plaintiff', lalatil/llB. a, Granting pOlsesslon of tho home located at 128 6. Second Street, WOlmleysbul'!1o Ponnsyll/anlll, 10 the plaintiff to the exclusion of I he dufendonl pending II 11nol oldel in t h 16 mo t till, 4, Order ,ng I he delendant to st ay away 110m any residence Ihe ploinl,ff may 1n the future estllblish for herself. B, Schedule a hUllllllij ,n /lccordonce with the provisions of the "Protoct,on Irom Abuso Acl ," and, lifter such he/lr1ng, onler on ordel to bH ill effect for 8 pOllOd of olle yeol: 1. ReQUit ,ng Ihe defendanl 10 refra1n Irom abusing the plaint I ff or plaCIng he, In leor of abuse. 2. ReQulIinll the defelldanl 10 lefraln from hlll/ln9 any contact with the pla1l1l,ff, illclud1ng, but not lImited to, reltroining Ihe doll/Ildonl 110m entellng Ihe pl811lliff's place of employmellt, 110m hllla5S111!l or stalking tho plllllltifl. end flom hlllll!l511l9 Ihe plaintiff's rellllives. 3. GIant Ing pOSBllSSlon 01 the house locuted 01 128 6, Second tHlllet, WOlml"ystHllll, Pell116ylvlllll/l, tll the plaintiff to the enlusiol1 01 the defel111al1t, 4 , 0 I d l' I i n [j t II tl d H f en d on t t 0 b I 0 Y II W II I' f I om llll I' 18Side11l,1l the pIal/iliff mill' 111 thu ftJIUlo l!stablllih fot hllllHtl f. Ii. 0llJUl1119 11111 flHltlnlJllll1 to lu1mbUl6ll Ihll nlatl1t1f1 1111 ,,","Ih of 1111/10] /lilt! 5UfYILIl of tl,ls I<<WllUl1 IllnJ In pIn PAULA BROWN, P18intiff vs. I IN TilE COURT OF COMMON PLEAS OF I I CUMBERLAND COUNTY, PENNSYLVANIA I I NO. 94 - 3306 CIVIL TERM I I PROTEC1'lON FROM ABUSE I I I ROBERT YEN FER, Defendant PROTECTIVE ORDER AND NOW, this lj'fl, day of June, 1994, upon consideration of the Consent Agreement of the parties, the following Order is enteredl 1. The defendant, ROBER1' YENn:Jl, is enjoined from physically abusing the plaintiff, PAULA BROWN, or from placing her in fear of abuse. 2. The defendant, ROBERT VENFER, Is enjoined from having any contact with the plaintiff, Including but not limited to, restraining the defendant from entering the plaintiff's place of employment, from harassing or stalking the plaintiff, and from harassing the plaintiff's relatives. 3. 'fhe defendant, IWBER1' YENI'ER, Is hereby excluded from the premises located at 128 South Second Street, Wormleysburg, Pennsylvania. The defendant is hereby notified that if he resides in the plaintiff's domicile contrary to this order, he may be in indlreet criminal contempt which is punishable by a fine not to exceed $1,000 and/or by a sentence of up to six months in jail and any other appropriate punishment. Resumption of co-residence on the part of the plaintiff and defendant shall not nullity the provisions of the court order direotin9 the defendant to refrain from abusing the plaintiff. 4. The defendant, ROBERT VENFER, is ordered to stay away trom any residence the plaintiff may establish for Ilorself in tho future. 5. The defendant is ordered to pay to the plaintiff cost of filing and service of this lawsuit in ths amount of $70.46 within sixty days of the entry of this order, 6. This Order shall remain in effect for a period of one year. 7. Tho Wormloysburg and Hampden Township Police Departments will be provided with a copy of this Order by attorneys for plaintiff and may enforce this Order by arrest for indirect criminal contempt without warrant upon probable cause that this Order has boen 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 taken without unnecessary dslay before the Court that issued the Order. When that Court is unavailable, the defendant shall be taken before the appropriate district justice (23 PB Bection 61131. By the Court ~ VB, I IN THE COURT OF COMMON PLEAS OF I I CUMBERLAND COUNTY, PENNSYLVANIA I I NO. 94 - 3306 CIVIL TERM I I PROTECTION FROM ABUSE I I I PAULA BROWN1 Plaint ff ROBERT YENFER, Defendant CONSENT AGREEMENT This Agreement is entered on this day of June, 1994, by the Plaintiff, PAULA BROWN, and the defendant, ROBERT YENFER, The plaintiff is represented by Joan carey, of Legal services, Inc., the defendant is unrepresented but is aware of his right to have an attorney. The parties agreo that the following may be entered as an Order of Court. 1. The defendant, ROBERT YENFER, agrees to refrain from abusing the plaintiff, PAULA BROWN, 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 plaintiff's place of employment. 3. The defendant agrees not to harass or stalk the plaintiff or harass the plaintiff'S relatives. 4. The defendant agrees to stay away from the residence loeated at 128 South Secend street, Wormleysburg, pennsylvania. 5. The defendant agrees to stay away from any residence the Plaintiff may establish for herself in the future. 6. The defendant agreee to reimburse the plaintiff all