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month~ In jail and nny other appruprlnte punl~hment, ~o9umptlon
of co-renlduncu on thu part uf tho plnlntlff nnd dofendant Bhall
not nUllify thu pruvlnl<lnn uf the court order dlrectlnll the
defondant to refrain from abunlnK the plaintiff,
4. Until Ileptcmber 2J, 1'1'14, the plaintiff will 6I'ranllc for
an apartment where the defendant may ntay provided that he
coopuraten and attendn counRellng BennlonR.
~, Thin order RIIlIII remnin In effect for a period of onB
year.
6. The Hnmpden Townnhip Police Department will be provided
with a copy of this Order by attorneys for plaintiff and may
enforce thin Order by arreRt for Indirect criminal contempt
without warrant upon probablu caune that thin order han been
violated, whether ur not the violation is committed In the
presence of the pollee officer, In the event thnt nn arrent Is
made under th IB Beet ion, the defendant Rhn II tnlten without
unneceBRary delay before the Court thnt iBBued the Order. When
that Court iR unllvallnble, the defendant Rhall be taken before
the appropriate diBtrlct Juntice (23 PS Section 611J).
By the Cour t
J.
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SUSAN D. CONNELLY
PI,'nU"/Petlllon.,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO, 84-4587
PROTECTION FROM ABUSE
v.
MARK P. CONNELLY
D.r.ndlnt/R..pondlnt
NAy 18 f995
')'I\-.1
..I.EMeO.8AflY. PROTECTION ORDER
~,j
AND NOW, this ~_ day of May, 1995, upon presentation and cO'1slderatlon
of the within Petition, and upon finding that the plaintiff, Susan D, Connelly, rellldlng
at 155 Salem Church Road, Lot 66, Mechanlcsburg, Cumberland County,
Pennsylvania, Is In Immediate and present danger of abuse from the defendent, Mark
p, CO",1elly, the following Temporary Order 15 entered, Law enforcement agencies,
human service agencies and school districts shall not disclose the presence of the
plaintiff In the Jurisdiction or district or furnish any eddress, telephone number, or any
other demographic Information about the plaintiff except by further Order of Court.
The defendant, Mark p, Connelly, (Date of Birth: May 15, 1953) now residing at
155 Salem Church Road, Lot 66, Mechanlcsburg, Cumberland County, Pennsylvania,
Is hereby enjoined from physically abusing the plaintiff, Susan D, Connelly, or placing
her In fear of abuse,
The defendant Is ordered to stay away from the plaintiffs residence located at
155 Salem Church Road, Lot 66, Mechanlcsburg, Cumberland County, Pennsylvania,
a residence which Is jointly owned by the parties,
The defendant Is ordered to refrain from having any direct or Indirect contact
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with the plaintiff Including, but not limited to, telephone and written communications,
The defendant Is enjolnfid from harassing and stalking the plaintiff and from
harassing the plaintiffs relatives,
The defendant Is enjoined from entering the plaintiffs place of
employmenl/buslness or school,
The defendant Is enjoined from removing, damaging, destroying or selling any
property owned jointly by the parties or owned solely by the plaintiff,
A vlolltlon of thll Order mlY lublect the defendlnt to: I) Irre.t under 23
PI. C.8. 66113j II) a private criminal complaint under 23 Pa. C,8.86113.1; III) I
chlrge of Indirect crlmlnll contempt under 23 PI. C.8. 66114, punllhlble by
Imprllonment up to six monthllnd I fine of $100.00.$1,000.ooj Ind Iv) civil
contempt under 23 Pa. C.S. 86114.1. Relumptlon of co-relldence on the plrt of
the plalntl" and defendlnt Ihall not nullify the provlllonl of the court order.
this Order shall remain In effect until modified or terminated by the Court after
notloe or hearing and, can be extended beyond that time, If the Court finds that the
defendant has committed another act of abuse or has engaged In a pattern or
practice that Indicates continued risk of harm to the plaintiff,
this Order shall remain In effect until modified or termlnatF.ld by the court after
11~ J~I t/--';1 .
notice or hearing, A hearing shall be hsld on this matter on the ,:'~ day of , 1905, at
(~I~Afr -
~:m" In Courtroom No,-.:, Cumberland County Courthouse, Carlisle,
Pennsylvania,
The plaintiff may proceed without pre-payment of fees pending a further order
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aller the hearing,
The Cumberlend County Sheriff's Department shall attempt to make service at
the plaintiff's request and without pre-payment of fees, but service may be
accomplIshed under any applicable rul19 of CIIIII Procedure,
this Order shall be docketed In the office of the Prothonotary and forwarded to
the Sheriff for service, The Prothonotary shall not send a copy of this Order to the
defondant by mall,
The Pennsylvania Glate Pollee and the appropriate local Police Departmenl/s
will be provided with a certified copy/certified copies of this Order by th$ plaintiff's
attorney, This Order shall be enforced by any law enforcement agency where a
vlolatlol1 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 unnecossery 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, 66113),
By the Court,
, Judge
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v.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
~ NO. 84.4587
PROTECTION FROM ABUSE
SUSAN D. CONNELLY
PI.lntlrr/Pelltlone,
MARK P. CONNELLY
Derendant/R..ponde"t
eJTlTION FOR PROTEc;TION ORDER
~p CUST.QD.Y
RELIEF UNDER THE PROTECTION FROM ABUSE
ACT, 23 P,S. 8 6101 et eeq.
{3. ABU,U
1, The plBlntlff, SuaBn 0, Connelly, Is Bn adulllndlvlduBI residing at 155
Saltem Church Road, Lot 66, Mechanlcsburg, Cumberland County, Pennsylvania,
2, The defendant, Mark p, Connelly, Is an adult with an unknown residence
but had been residing at 155 SBlem Church ROBd, Lot 66, MechBnlcsburg,
Cumberland County, PennsylvanlB,
3, The defendant Is the husbBnd with the plBlntlff although a divorce
petition hBs been flied In CumberlBnd County,
4, Since approximately April 1 , 1995, the defendant has attempted to cause
and has Intentionally, knowingly, or recklessly cBused bodily Injury/serious bodily
hBrm. to the plaintiff or has placed the plaintiff In reasonable fear of Imminent serious
bodily Injury, this has Included, but Is not limited to, the follOWing specific Instances
of abuse:
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cau.ed the petitioner to fear that he might attempt to permit an air
bubble to contaminate the syringe which would oause slgnlfloant
physloallnjurles possibly Irlcludlng death: and
f, On April 11 , 1995, the Hampton Township Police were lSummoned
to the marital residence to respond to the pelllloner's fearls of abuse and
the respondent was asked to leave the home,
g, On or about May 1, 1995 the parties came to a verbal agreement
that oertaln property would be divided In an altemptto resolve future
equitable dlstrlbullon, As a part of that verbal agreement, the defendant
agreed to refrain from contacllng the plslnllff and four of the plaintiffs
olosest friends, In exchange, the plaintiff would drop the Protecllon
From Abuse petition which was tiled on April 19, 1995, Although the
defendant had not signed the agreement, defendants Gounsel stated
that he would sign for the defendant and consummated the agreement.
Once the verbal agreement was reduced to written form and presented,
the defendant refused to sign the agreement unless addlllonalterms
were added, The additional terms were unacceptable to the plalnllff and
she denied a modification, Since the alleged .agreement," defendant
has contacted persons he agreed not to contact. Defendant was also
recenlly observed sitting In his truck near the entrance to the plaintiffs,
I, As a result of the above stated, the plaintiff Is In great fear of the
defendant snd Is generally unwilling to leave her house,
15, The plaintiff believes and therefore allers that she Is In ImmedIate and
present danger of abusB from the defendant shOUld she remain In the home without
the defendanfs exclusion 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, and from harassing the plaintiffs relatllles,
6, The plaintiff desires that the defendant be restrained from entering her
place of employment/business or school.
9, The plaintiff desires that the defendant be enjoined from remolllng,
dameglng, destroying or selling any property owned Jointly by the parties or owned
solely by the plaintiff,
B. EXCfLUSIVE POSSESSIQN
10. The mobile home from which the plelntlffls asking the Court to exclude
the defendant Is owned In the names of Susan 0, Connelly and Mark p, Connelly,
11, The plaintiff desires possession of the mobile home so as to gllle the
greatest degree of continuity to the life and to allow her to continue her education at
her school and to continue her social activities,
Of j.OBIIES/ATTORNEV FEEl
12, The plaintiff allkll that the defendant be ordered to pay reasonable
attorney fees to Peter RUSIIO, Esqulro,
1 G, An award under this chapter sholl not constitute a bar to litigation for olvll
damages for InJurlos sustained from the acts of abuse giving rise to the aWard or a
finding of oontempt undor this chapter.
WHEREFORE, pursuant to the provisions of the "Protection from Abuse Act" of
October 7,1976,23 P,S, ~ 6101 gj H.Q" as emended, the plalnllff prays this
Honorable Court to grant the follOWing relief:
A, Grant a Temporary Order pUlsuantto the "Protecllon from Abuse Act:"
1, Ordering the defendant to refrain from abusing the plaintiff and/or
placing her In fear of abuse;
2. Ordering the defendant to refrain from haVing any direct or
Indlreot contact with the plalnllff Including, but not limited to, telephone
and written communications;
3, Ordering the defendant to refrain from harassing and stalking the
plaintiff and from harassing the plaintiffs relatives;
4, Prohibiting the defendant from entering the plaintiff's place of
employment/business or Bchool;
5. Prohibiting the defendant from removing, damaging, destroying or
selling property Jointly owned by the parties or owned solely by the
plaintiff;
6. Granting possession of the home/apartment/mobile home looated
at 165 Salem Church Rand, Lot 66, Mechanlcsburg, Cumberland
County, Pennaylvanla, to the plaintiff to the exclualon of the defendant
pending a IInal order In this matter;
7, Ordering the defendant to stay away from the plaintiffs residence
looated at 155 Salem Church Road, Lot 66, Mec:hanlcaburg, Cumberland
County, Pennsylvania, which the parties have shored;
8, Ordering the defendant to stay away from any residence the
plaintiff may In the future establish for herself;
8, Schedule a heerlng In accordance with the provisions of the .Proteotlon
from Abuse Act," and, alter such hearing, enter an order to b8Be In effect for a
period of one year:
1, Ordering the defendant to refrain from abusing the plaintiff and/or
placing her In fear of abuse,
2, Ordering the defendant to refrain from having any direct or
Indirect contact with the plalnllff Including, but not limited to, telephone
and written communlcallons,
3, Ordering the defendant to refrain from harassing and stalking the
plalnllff and from harassing the plalnllffs relatives,
4, Prohibiting the defendant from entering the plaintiffs place of
employment/business and/or school.
5, Prohibiting the defendant from removing, damaging, destroying or
selling property jolnlly owned by the parties or owned solely by the
plaintiff,
6, Granting possesslotl of the home/apartment/mobile home localed
01155 Salem Church Road, Lot 66, Mechanlcsburg, Cumberland
Counly, Pennsylvania, to the plalnllff to the exclusion of the defendant.
7, Ordering the defendant to stay away from the plalnllff's residence
localed at 155 Salem Church Road, Mechanlcsburg, Cumberland
Counly, Pennsylvania, which the parties have shared.
e, Ordering the defendant to stay away from any residence the
plaintiff may In Ihe future establish for herself,
9, Ordering the defendant to pay reasonable attorney fees 10 Peler
Russo, Esquire,
Tho plaintiff further asks that this Pellllon be flied and served without pre-
payment of fees by the plalnllff, and that a certified copies of this Pellllon and Order
be delivered to the appropriate pollee department(s) who have Jurisdiction to enforce
this Order,
The plaintiff prays for such other relief as may be just and proper.
SUSAN D. CONNELL V
Pl"ntlff/p.tlllon,r
v.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 84.4597
PROTECTION FROM ABUSE
MARK P. CONNELLY
D,'endlntlR'lpond'nt
fBOTECTION ORDER
AND NOW, this _ day of May, 1996, upon consideration of the Consent Agreement
of the parties, the following Order Is entered:
1, The defendant, Mark p, Connelly, Is enjoined from physically abusing the
plaintiff, Susan D, Connelly, and/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 and
from harasr;lng the plaintiffs relatives,
4, The defendant Is prohibited from entering the plaintiffs place of employment,
business and school,
6, The defendant Is prohibited from removing, damaging, destroying or selling
any property owned by the plaintiff or Jointly owned by the parties,
6, The defendant Is excluded from the plaintiffs residence located at 165 Salem
Church Road, Lot 66, Mechanlcsburg, Cumberland County, Pennsylvania,
7, The defendant Is ordered to stay away from the plaintiffs residence located at
155 Salem Church Road, Lot 66, Mechanlcsburg, Cumberland County, Pennsylvania, which
the partie. have shared,
B. The delendant Is ordered to stay away from any resldenca the plalnllff may In
the future establish for harsell,
9, This Order shall remain In effect lor a period 01 one year or until modified or
terminated by the Court alter nollce or hearing and may be extended beyond that lime lithe
Court finds that the defendant has committed another act 01 abuse or has engaged In a
pattern or pracllce that Indicates continued risk 01 harm to the plalnllff,
10. This Order may subject tho delendant to: i) arrest under 23 Pa, C,S, g611'3; II)
a private criminal complaint under 23 Pa, C,S, g6113,1: III) a charge 01 Indirect criminal
contempt under 23 Pa, C,S, g6114, punishable by Imprlsonmont up to six months and a line
of $100,00-$1,000,00; and Iv) civil contempt under 23 Pa, C,S, g6114,1, Resumption of co-
residence on the part of the plaintiff and delendant shall not nullify the provisions 01 the
court order,
12, The appropriate police department(s) shall be provided with certllled copies of
this Order by the plaintiffs attorney and may enlorce this Order by arrest lor Indirect criminal
contempt without warrant upon probable cause that this Order has been violated, whether or
not the violation Is committed In the presence 01 the police officer, In the event that an
arrest Is made under this secllon, the delendant shall be taken without unnecessary delay
before the court that Issued the order, When that court Is unavailable, the defendant shall
be taken belore the appropriate district Justice, (23 P.S, g 6113),
By the Court,
,Judge
v.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 84.4587
PROTECTION FROM ABUSE
SUSAN D. CONNf,LL Y
Pllln""/Petltloner
MARK P. CONNELLY
Dlfendlnt/Re.pondent
CONSENT ~GREEMeNT
This Agreement Is entered on this _ day of May, 1995, by the plaintiff, Susan 0,
Connelly, and thl'l defendant, Mark p, Connelly, The plaintiff Is represented by Peter Russo,
Esquire the defendant is represented by Bruce A, Grove, Jr" Esquire, The parties agree that
the following may be entered as an Order of Court,
1, The defendant, Mark p, Connelly, agrees to refrain from abusing the plaintiff,
Susan 0, Connelly, and/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 harass and stalk the pla221ntlff and harass the
plaintiffs relatives,
4, The defendant agrees not to enter the plaintiffs place of employment, business
and school,
5. The defendant agrees not to remove, damage, destroy, or sell any property
owned by the plaintiff or jointly owned by the partlee,
6. The defendant agrees to stay away from the plaintiffs residence located at 155
Salem Church Road, Lot 66, Mechanlcsburg, Cumberland County, Pennsylvania, which the
parties have ehared,
und lUllIlth hy numerllU~ l'UNlucts uf phYNlcul vlolcncc ,lnd ~fJnllnuullhreUlsllf tlllng SPUrlOUN
erhnhllllund civil churges ug'llnsl him," (Emphusls ours)
6, On Muy 25, 1995, lhe purtlcN hercto uppeurcd hcforc lhe Hunomhlc George E,
Hoffcr, with Ihe rcspccllve cllunscl. Inunllcllun fIIcd undcr lhc Prulccllun From AhuNe Act,
23 Pu, C,S. ~ ClIOI Cl NCq.
7, Onthc ufurcmcntluncd dUlc II Flnul Prulcctlun Ordcr wus entercd IIguhlsllhe
Rcspundcllli u truc und currccl cupy lIf the Ordcr Is ulluchcd hcrclo, mude II pUrl hcreof, und
murked Exhlhlt "A,"
8, PClltluncr ullcgcN thul slncc Ihc cnlry uf suld Ordcr, thc Respundent hUN vlolulcdit
inlhe fullowing nHlIlncr:
II. Inuccurduncc with Ihe uhllvc-rcfercnced dlvurce ucllun Nel uUllu pllrugruphN 4 lllld
S, ubovc:, undersigncd cuulINclun hchlllf uf PClllluner und Peler}. Russu, Esquire, un hehulf
of Respundcnl, cunduclcd unguing ncgulhlll<llls rcllllivc IU 'III Divurce Cude Issues Inurdcr
lhul u fair und cqultuhle PrllpcrlY Sclllcmcnl Agrccmcl1l cuuld hc rCllchcd.
h. As u rCNulluf lhcsc unguing ncgutialions, on OCluhcr 31. 1995, Mr, Russu wrUlC
Mr, Grovc udvislng, inlcr allll, IIHlI ." "This wlllllng pruccss und cunslunl I'e-ncgulluling hllN
hroughtmy diel1lto II SIUIC of \allulillnulullllul6h which mllY rcquirc sumc ~lIunse\lng."
<Emphasis lIurs)i u CllPY uf this IcUel' is uuuchcd hcrclu, madc u purl hcrellf, l\Ild l11arked
Exhihit "II,"
C. On Novcmhcr 17, 19<)5, Ul UhUUlII:20 11.111" Mr. Grllvc rccclved Illclepholle cull
from Mr. I~ussll. cllunscl I'llI' I~espllndcnl, IIlld he IIdviscd he hud his cllclll 1111 the lelephlllle
ulld that she 11IId jusI sHlledl1l him (Mr. Russll) lhlll "shc Wlluld kill Murk" if shc "hlst" the
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IN THI cOURT or COMMON PLIAS or
cUMBIRL~ND COUNTY, PENNSYLVANI~
NO. 114-41597
PROTECTION FROM ABUSE
BUlAN D. CONNILLY
Plaintiff/petitioner
MARK P. CONNELLY
Defendant/Respondent
__TI'JKI'9 R1\R lLI'R9TIlQ'l'191t.9RQIlR
AND NOW, this __Lt'.. duy ot April, 1995, upon presentation
and considoration of tho withln potition, and upon tinding that the
plaintiff, Susan D. connelly, residlng at 155 Salem Church Road,
I,ot 66, Mechan icsburg, cumborland county, Pennsylvania, ilil in
immediate and presont dangor of abuso trom the defendant, Mark p,
connelly, the following 'l'emporary Ordor is entered, Law
enforcement agencies, human sorvice agencies and school districts
shall not disclose the presence of the plaintiff in the
jurisdiction or district or furnish any address, telephone number,
or any other demographic information about the plaintiff except by
further Ordor of Court,
'l'he defondant, Mark P. connelly, (Date of Birtht May 15, 1953)
now residing at 155 Salem Church Road, I,ot 66, Mechanicsburg,
Cumberland
County, Pennsylvania, is hereby enjoined from
phyoically abus ing the pla intif f, Susan p, connelly, or placing her
in fear of abuse.
f1 ..!1'A~ d~f~l,ddnt; is eXClUded trom and 113 oraerea Lv Bt.ay a\:a.y
fraM tAg pl~~R~iff/~ r99~~~RgQ locatgQ a~ 155 EalQm CR~rgn RS3d,
r Let 66, UeeR~t"'\;~Ahllra. CymberlRnd
County
Pont:l;prl"a~;:tr A
k6.:5id4!hGI;;l: whlch it:) joinLly ',Jvd,~J J...,} tlJ~ parties.
The def~ndant is ordered to refrain from having any direct or
indireot contaot with the plaintiff including, but not limited to,
telephone and written communications.
The defendant is enjoined from harasainq and stalking the
plaintiff and from hurnsBinq tho plnintiff's rolativos.
The defendant is enjoined from entoring the plaintiff'S place
of employment/buBincB~ or. school.
The dofcndant is onjoinod from romovLnq, damaginq, destroying
or selling any proporty ow nod jointly by the parties or owned
solely by the plnintiff,
A violation of this Order may subject the defen~ant to, i)
arrest under 2J Pa. O.S. 66113/ ii) a private criminal complaint
under :Z3 fa. O,S. 66113.1/ ili) a oharge of indirect oriminal
contempt under 23 Pa. o.S. 66114, punishable by imprisonment up to
eix months and a fine of $100.00-$1,000.00/ and iv) civil contempt
under 23 Pa. C.S. ~6114.1. Resumption of co-residence on the part
of the plaintiff and defendant shall not nullify the provisions of
the court order.
This Order shall romain in cffect until modifiod or torminated
by the Court aftor notico or hoaring nnd, can be extcnded boyond
that time, if tho Court finds that the dotondanC has committed
another act of abuso or has enqaged in a pattorn or practice that
indioates continued risk of harm to tho plaintiff.
'rhis Order shall romain in offect until modified or terminated
by the court after notice or hearing. A hearing shall be held on
this matter on the ,'.7/1> i
)
day of May, 1995, at .'j,)(1
.) ,m., in
,
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courtroom No. _
P'mnsylvania.
The plaintlff may prooeod without pre-payment of fees pending
a further order after tho henrlnq.
cumIJerlnnd
county
courthouse,
Ca rUde,
The Cumberland county shoriff/s Dopartmont shall attempt to
make service at tho plnlntlff/s request and without pro-payment of
foos/ but sorvico may bo nccomplished under ony applicabLe rule of
civil Proceduro.
This Ordor shall bo dockotod In tho offke of tho prothonotary
and forwardod to tho Shoritf tor sorvico. Tho Prothonotary shall
not send a copy of thls Order to tho dofondant by mail.
The appropriato Polico Dopartment(s) will bo provldod with a
oertified copios ot this Ordor by the pLnintiff/s attornoy. This
Order shall bo on forcod by nny Inw rm torcomont agency where a
violation occurs by arrost for indlroct criminal contompt without
warrant upon probable cause that this Ordor h[H3 been violated /
whether or not the violation is committed in tho presonce of the
police officer. In tho ovent that nn orrost ia mado, under this
seotion, tho defendant aha 11 bo tokon wi thol.lt unnecossary delay
before the court that issuod tho ordor.
When that court is
unavailable, the do fondant shall bo tokon bofore the appropriate
distriot justice. (23 P.B. ~ 6113).
, Judge
v.
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IN TNI COURT OF OOMMON PLEAS or
OUMBIRL~ND OOUNTY, PENNSYLVANIA
NO. 114-4597
PROTEOTION FROM ABUSE
BUB~H D. CONNELLY
plaintiff/Petitioner
HARK P. CONNELLY
Defendant/Re.pondent
NOTIOE
You have been sued in court. If you wish to de fend against
the claims set forth in the fOllowing pages, you must take action
promptly after this Petition, Ordor and Notico are served, by
appearing personally or by attornoy at the hearing scheduled by
the Court and presenting to tho Court your defenses or objections
to the claims set forth against you. You are warned that if you
fail to do so tho Court may procood without you, and a judgment
may be entered against you by tho Court without further notice
for any money claimed in tho Petition or for any other claim or
relief requested by the plaintift. You may lose money or
property or other rights important to you.
lEES 1\ND COSTS
If the case goes to hearing and the judge grants a
protection Order, a surcharge of $25.00 will be assessed against
you. You may also be required to pay attorney fees to Legal
Services, Inc. for their representation of the plaintiff.
You should take this paper to your lawyer at onoe. If you
do not have a lawyer or cannot afford one, go to or telephone the
office .et forth below to find out where you oan get legAl help.
COURT ADMINISTRATOR, 4th FLOOR
CUMBERLIIND COUN'l'Y COURTHOUSE
CARLISLE, PENNSYLVANIA 17013
TELEPHONE NUMBER: (717) 240-6200
v.
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IN TH! OOURT OF OOMMON PLIAB or
OUMBIRL~ND OOUNTY, PINNBYLVANIA
NO. 114-45117
PROTEOTION FROM ~BUSE
.U8lH D. CONNELLY
plaintiff/petitioner
NARI P. CONNILLY
Defen4ant/Re.pondent
I'II.T.I'U9.tt ..'9R-..I'MTflfJ'RJ,QILQ,RJ;lflR
RELIEF UNDER THE PROTECTION FROM ~BUSE
ACT, 23 P.S. Ii 6101 et seq.
Tu_^IlYJUJ
1. The plaintiff, Sllsnn D, connolly, is an adult individual
residing at 155 Slllem Church Rond, Lot 66, Mechanicsburg,
cumberland County, Pennsylvnnill,
2. The defendant, Marl( 1'. Connolly, is an adult individual
residing at 155 Salem Church Road, Lot 66, Mechanicsburg,
Cumberland County, Ponnsylvania,
3. The defendant is the husband with the plaintiff.
4. since approximatoly April 1, 1995, the defendant has
attempted to cause and has intentionally, knowingly, or recklessly
caused bodily injury/serious bodily harm, to the plaintiff or has
placed the plaintiff in reasonable fear of imminent serious bodily
injury, This has included, but is not limited to, the following
specific instances of abllsot
a. Respondont constantly uses foul and abusive language
which intimidates tho potitionerl
b, The respondent's use of alcohol and hiB use at
toul and abusive language has led to other alt~rcationB bQtween
the parties and has caused the petitioner to fear for her safety,
c. Respondent stated to the petitioner that "you don't know
when you arc going to get it" which hae caused the petitioner
furth,r ooncern over her safety,
d. Respondent has callod petitioner's friends saying
that the potitioner was going to pe alone for the weekend and
that he thought the petitioner might inflict some harm on
herself. This has also causod the petitioner to fear for her
safety in that it appoars us though the respondent might be
laying the groundwork for an alibi,
e, Petitioner is roquired have migraine medication
injected into her bloodstroam. The rospondent typically injected
the petitioner. Recently the respondent took an excessive amount
of time preparing the needle for the injection, When the
petitionerwent into the kitchon to invostigate, she notice that
the needle was not put together right which caused the petitioner
to fear that he might attempt to permit an air bubble to
oontaminate thesyringo which would causo significant physical
injuries possibly including deathl and
f, On April 11, 1995, the Hampton Township Police
We~8 summoned to the marit"l rosidonoe to respond to the
petitione~'s fea~s of abuse and the respondont was asked to leave
the home.
5. The plaintiff believes and therefore avers that she is
in immediate and present danger of abuse from the defendant
should she remain in the home without the defendant's exclusion
and that ahe is in need of protoction from auch 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, and from harassing the
plaintiff's relatives,
8. The plaintiff desires that tho defendant be restrained
from entering her place of employment/business or school.
9. The plaintiff desires that the defendant be enjoined
from removing, damaging, destroying or selling any property owned
jointly by the parties or owned solely by the plaintiff.
B. EXCLUSI~OSSEBSIQN
10. The mobilo home from which the plaintiff is asking the
Court to exclude the defendant is owned in the names of Susan D.
Connelly and Mark p, Connelly,
11. The plaintiff desires possession of the mobile home so
ae to qiv8 the greatest degree ot continuity to the lite and to
allow her to continue her education at her school and to oontinue
her sooial activities,
~~>>Ba/~TTORNEY FIlS
12. The plaintiff asks that the defendant be ordered to pay
reasonable attorney fees to Peter Russo, Esquire.
13. An award undor this chaptor sholl not constitute a bar
to litigation for civil damagos for injuries sustainod from the
acts of abuse giving riso to tho award or a finding ot contempt
under this chapter,
WHEREFORE, pursuant to tho provisions of the "Protection
from Abuse Act" of octobor 7, 1976, 23 P,S. ~ 6101 ~ ~'I 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 r "
1. Ordering the defendant to refrain from abusing the
plaintiff and/or placing her in fear of abuser
2, Ordering the defendant to rofrain from having any
direct or indiroct contact with the plaintiff
inClUding, but not limited to, telephone and written
communicationsr
3. Ordering the defendant to rofrain from harassing
and stalking the plaintiff and from harassing the
plaintiff's relativesr
4. Prohibiting the defendant from antering the
plaintiff's place of employment/business or sohool/
5. Prohibiting tho defendant from removing, damaging,
destroying or soiling property jointly owned by the
parties or ownod sololy by tho plaintiff/
6, Granting possos~ion of tho home/apartment/mobile
home located at 155 Salem Church Road, Lot 66,
Mechanicsburg, Cumborland county, ponnsylvania, to the
plaintiff to tho exclusion of tho defendant pending a
final order in this mattor;
7. ordering the dofendant to stay away from the
plaintiff'S residence located at 155 Salem Church Road,
Lot 66, Mechanicsburg, cumberland county, Pennsylvania,
which the parties have shared;
8. Ordering the defendant to stay away from any
residence the plaintift may in the future establish for
herself;
B. 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 n period of one year:
1. Ordering the defendant to refrain from abusing the
plaintiff and/or placing her in tear of abuso.
2. Ordering the defendant to refrain trom having any
direct or indirect contact with tho plaintiff
incLUding, but not limited to, telephone and written
CQmmunication~.
3. ordering the defendant to refrain from harassing
and stalking the plaintiff and from harassing the
plaintiff'S relatives.
4. Prohibiting the defendant from entering the
plaintiff'S placo of employmont/business and/or sohool.
6. prohibiting tho defendant from romoving, damaging,
destroying or solling proporty jointly owned by the
parties or owned solely by the plaintiff,
6. Granting possossion of tho homo/apartment/mobile
home located at 155 Salem Church Road, Lot 66,
Mechanicsburg, Cumberland county, ponnsylvania, to the
plaintiff to the exclusion of the defendant,
7. Ordering the defondant to stay away from the
plaintiff's residence located at 155 Salem Church Road,
Mechanicsburg, Cumberland County, Ponnsylvania, which
th~ parties have shared,
8. Ordering the defendant to stay away from any
residence the plaintiff may in the futuro establish for
herself.
9, Ordering the defendant to pay reasonable attorney
fees to Peter Russo, Esquire.
The plaintiff further asks that this Petition be filed and
served without pre-payment of fees by the plaintiff, and that a
certified copies of this Potition and Order be delivered to the
v.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 94.41597
PROTECTION FROM ABUSE
SUSAN D. CONNELLY
Plllntlff/PeUUoner
MARK P. CONNELLY
Oefendlnt/Re.pondent
fBmECTlVE ,ORDER
AND NOW, this day 01 April, 1995, alter hearing on petllloner'lf Petition
for Relief, the lollowlng Protection Order Is hereby entered:
(1) The respondent, Mark p, Connolly, Is directed to relraln Irom:
(a) having personal contact, tolephono contact and any other contact
with the petitioner and from entering the place of employment,
business or school 01 the potltloner;
(b) attempting to cause or Intentionally, knowingly. or recklessly causing
bodily Injury or serious bodily Injury with or without a deadly weapon
to the petitioner and/or the minor chlld(ren) 01 the parties:
(0) physically abusing or menacing the petitioner thereby placing her In
fear 01 Imminent serious bodily Injury and;
(d) enjoined Irom harassing the petitioner as dellned In 1 B Pa. C.S,A,
section 2709.
(2) The petitioner, Susan D. Connelly, Is hereby given exclusive possession 01
the marital residence located at 155 Salom Church Road, Lot 66, Mechanlcsburg,
Pennsylvania, and the respondent, Mark P. Connelly, Is hereby evicted 'rom said
premises and directed not to enter thereon during the duration 01 this Order or until
lurther Order 01 the Court.
(3) This Order shall not In any manner affect title to any real property owned
by the parties,
(4) This Protection Order shall remain In effect until one year Irom the signing
01 this Order.
SUSAN D. CONNELLY, I IN THE COURT OF COMMON PLEAS OF
plaintiff I
I CUMBERLAND r,:OUN'l'Y, PENNSYLVANIA
I
VII. I NO, 94-4597 CIVIl, 'rERM
I
I PROTECTION FROM ABIISE
M.\RK P. CONNELLY, I
Defendant I
MOT I Oti...fll.B.....c.Qli'U N UANC E
The plaintiff moves this Court for an Order oontinuing the
hearing of this oase until further order. of court, on the grounds
thatl
1. A Temporary Proteotive Order was issued by this Court on
the 15th day of August, 1994, schedUling a hearing for the ~3rd
day of August, 1994, at 4100 p.m.
~, The defendant was served with the Temporary Proteotive
Order but is currently receiving in-patient rehabilitation
treatment at Columbia University Hospital and will not be
released until at least September 9, 1994.
3, Family of the defendant contacted the Family Law Clinio
and requested a continuance on the defendant's behalf. The
Family Law Clinic is not representing the defendant at this point
in time,
4. The plaintiff is in agreement with a continuance until
the defendant is released from treatment on condition that the
Temporary Protective Order of August 15, 1994, remain in effect
pending further Order of. Court,
5. A copy of the Order for continuanoe will be delivered to
the Hampden Township Police Department by attorneys for the
Luter thllt mOl'Jllni, the defelldant was IInlll'Y at the pllllntlff and threatllnlld
tho plahlllff s/lylni thllt If hu W/lS II I'I'U II t lid , she was donll. lie 111110 threatened
ttlllt he would "fix \lIt 50 thllt her I'lIlutlvc!I would never havo any U'llltBct with
hor, CUUIIIIIIl the p111111tlff to 1'11111' for hcr slIfely.
b. (lJ) or IIbuut AUllust II, 1')'/4, the tlcfendllnt lit tempted to llaln entry to
the I'csldellce alld threlltened thllt If the pllllnllff tlldn't lilloII' him ontry, sho
hlld had It. The dcfendlllll then thl'lIW II bowl llf fontl lit thc plaint Iff and when
IIho went Into the lJuthroom to cllllln up, thu ddcndllnt Clllle hehind hilI', grabbed
hor lJy thu neck, slllmmud her Into the clIlJlnllt IInd sink, IIttemptlng to force her
heo Into lhe watur. The pllllntlff strullllled with the defendant to prevent her
flleu from llolnll Into the wlltur, The dufcndunt ugaln IIhoved the p161ntlff Into
the cllblnet IInd gruhhed hcl' IIrm. When the pllllnliff was IIble to break frell 1'1'011
lhe defendllnl, she rlln Into thc living nlllm and thc defendunt ran ufter her. for
her s/lfely, the p11lintlff telupholled the (XII Ice. The plaintiff Iluffered brulllllll
t<l her fuce, knell. /lntl thigh. und soreness to her ncck /lnd shoulders.
c. 111 or IIround the lJuglnning of July 1994, the defendant used his body
to push the pl/llntlff arllund the room and b/lck her Into a wall, c/lUlllng the
plaint I ff to fellr for hcr 1l11fety,
d, Inllr 'lround May 1994, the dcfendant sexually 6ssaulted the plaintiff.
5, The plaint I ff he I ieves and therefore uvcrll that shc Is In Il1lIIledlate
and present dllngcr of abuse from the defendant shou Id she remain in the hollC
without thedefendunt's exclusion and that she is in need of protection from such
abuse,
6, The p11lintlff desires thllt thl! defendant be prohibited from having
any contact with the plaint Iff, except by mall.
7, Thll plllinllff dOHlrll/! thllt tho dol'llndllllt he enjlllnod from h/ll'lI6111lnl&
I1nd IItlllklnll lhll pllllntiff, nnd from tUIl'IIRlling tho pll1lnlll'l"1I 1'11.11)'.
6. 'rhe pllllnllff ,llllllrllll th/lt lho dllfendant bll rostrlllnlld from Intlrlnl
her 1llllCIl of Ilmploymonl,
11,_ .JM,Ulllm.J~IUIBllII~
9. Thll mobile hOllo from whkh tho plaint I,.,. III 'liking the Court to
exclude the defcndtlJlt III ownod In thll IUIlnOH uf SUSAN n. OONNI\J.LY ANn MARK P.
CONNELLY,
\\1iEREfORE, (lurllu/lnt to thl.! provllll'lIlS of thll "l'rotllctloll from Aoosll Act"
of October 7, 1<)76, 23 P.S, U 610! Ill. riJl.!!., /Iii IIl1lCndlld, the pl/llnt i 1'1' prll)lli this
Honorable Court to grnnt thlt fo11llwlng rdillfl
A, Ornnl a Tempurtlry Ordllr pUrllU/lnl to the "Protecllon 1'1'011 Abuse
Act I"
1. Ordlll'lng the ddendant to refrain 1'1'011 IIbulllng the
plaint! ff 01' placing hilI' In fenr of nbullcl
2, Ordering thll dllfclltlnnl 10 refrtlln 1'1'0111 havlnM contllct
with the 1l1nlnllff, exccpt by mill II
J. Ordering thl! defendant to I'llfrain 1'1'011I hal'llslllnll IInd
stalking thll plnintlfl' /lnd from harassing thll plaintiff's
fllfllllYI
4, Prohibiting the derllndant from entering the plaintiff's
place of employment;
5. Gr/lnt i ng poSBllllS ion of the lIlublle home located at 155
Salem Church Rond, Lot '66, Mech8nlcsburg, Cumberland County,
Pennsylvania, to thc plaintiff to the exclusion of the
defendant (lending II flOlll order In this mattcl'land
el. onlurlnll thu ,lllfll/lllllnt to utllY IIWIIY f1'OlI1 IIny rlllllduncu
thll pllllnlirt' IlIIY In thu rutuu uutlllJIlllh for hursulfl
8, Bchudulu s hUllrlnl! In IIccord,lOuu with lhu lll'llvllluns of the
"protection frum Ahullu ACl," lind, IIftur lIuch huurlnM, untilI' an ordur
to bet In crruet 1'01' II period or une YUIII'I
I. Ordurlnl! lhu dllrendllnt to rufrllin frQIII abUIIlnll thu
pllllntiff or Illnclllll her In fllllr of "bullul
2. Onlur Inll the: dllfe:nd/lnt to rufl'llln from hllvlnM any
contllct with thc plalnlirt'. excupl by msi II
3, onlllrln!l. lhu defundant to refrain from harulllng and
stalking lhe plullltlrt' IInd rmm hurlllllllnll thu plaintiff's
famllYI
4. Pruhlbit In!l. the: defcndant rrollllnterinllthc p1alntlff'lI
place: of umployrnunt I
S. Ol'llllt I ng POIIIICIIII ion nr thu mob lIc hOle located at US
Sa1u. Church Rand, Lut *66, Muchllnlcsbur8, Cumberland County,
Pennllylvanla, to the plulntirr tu the exclulllon of the
dufllndant I
6. Orderlng the defendant to stay IIWIIY from any rCllldenCCl
thu pllllntlrf muy In thu future cstabllBh for herllc If I
The plaintiff further aBkB thllta certified copy uf this Petition and Order
be delivered to the Ifllmden Townl;hlp Police Department who have jurlsdlctlon to
enforce this Order.
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7, Admitted with qualifications. While Respondent admits an Order was
entered by the Honorable George E. Holter, the Ordel' allached by petitioner's counsel
has not been conformed nor does It contain the signature of any Judge, let alone the
signature 01 the Honorable George E, Hofler,
8, Denied, Respondent has not violated the Court's May 25, 1995, Order In
any way,
8a. Admllled with quallllcatlons, While It 15 admitted that "negotiations"
were ongoing, It 15 speclllcally denied that Respondent violated the Court's May 25,1995,
Order during the coul'se of these "negotiations,"
8b, Admllled with qualifications, While It Is admitted that counsellor the
Respondent sent a leller to petitioner'S cour,sel and said document speaks for Itself, It
15 specifically denied that this was violation tl1e Court's May 25, 1995, Order,
Bc, Admllled in port and denied In part. It Is admitted that on November
17,1995, at or about 11 :20 a,m., Respondent's counsel contacted petitioner's counsel
regarding a conversation Respondent's counsel had with the Respondent. It 15
specifically denied that counsel for the petitioner's version of the conversation 15
accurate, considering It has baen removed from Its context and only portions 01 the
conversation have been provided,
9, Denied, The averment at paragraph 91s a conclusion 01 law and no answer
Is required,
..
WHEREFORE, Respondent respectfully requests that this HonorabhJ Court
dismiss the Mark p, Connelly's Petition tor Indirect Criminal Contempt end Impose
sanc;\Ions on Merk p, Connelly. In the allernetlve, If this Honorable Court should decide
not to dismiss the cherges, considering the lects as detailed In the Instant Petition are
In dlBplJte, Respondent would ruquest that on order be entered, os provided by Aule
206,7 of the Pennsylvenla Rules of Civil Procedure, to obteln discovery Information from
petitioner's counsel.
tiE.w....MAIIEB.
10. This Honorable Court's Order or May 25, 1995, requires In the third
unnumbered paragraph of Petitioner's Exhibit A, that ", , , plaintiff [Susan DeMond
Connelly] agrees that she shall be excluded from defendant's residence, , ,"
11, The Petitioner has fnlthfully complied with sold portion this Honorable
Court's May 25, 1995, Order.
12, This Honorable Court's Order of May 25, 1995, requires In the fourth
unnumbered paragraph of Petltfonel"s Exhibit A" that "The parties agree that all contact
between eech other shall be had between their attorneys."
13, The Petirioner hus faithfully complied with said portion this Honorable
Court's May 25, 1995, Order end has not had any contact with the petitioner,
14, At no time did the Respondent violate any provision of this Honorable
Court's May 25, 1995, Order,
3
..
16, On or about Novllmber 17, 1995, counsel for the Respondent received
Information from the Respondllnt of a contingent ond futuristic act,
16, Believing Ihat physical hurm might come 10 another, albeit contingent on
various events lmd In the very distant luture, counsel for the Respondent advised the
Respondent that if she did not retract the statement Immediately, counsel would be
required to Inform petllloner's counsel of the statement. Respondent did not retract the
statement,
17, Counsel for the Respondontthen contacted counsel for the petitIoner and
advised him of the recent developments, and although concerned, Indicating that this
was 50 far Into the future It was nothing to be worried about and requested that petitioner
aid his wife [the Respondent] In obtaining medical assistance for depression,
18, The petitioner attempted to file criminal charges with Sergeant Andreoli of
the Hampden Township Police Department.
19, Sergeant Andreoli refused to accaptthe chargas from the petitioner and
sent the petitioner home,
20, Petitioner then flied the instant petition as an wrongful use of civil
proceedings, abuse of process, and In an eHortto further distress the Respondent.
4
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