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HomeMy WebLinkAbout94-06031 " I <'1,< ., ..' ,I 1,,11 ',I ,I-I' I'; 1>, , , ',I, i" , , , '1 , , , " \' '.' \',';I! , :,' " . , .,. .. :1 I;' ,I "I " \ I, " ..' " ., , ',-I' " I'. , , , i i " r ',' j ," l " .\ " , i , 1 I I , .-.; [ ""_.'~~i , , S I 1 .' l , ~-;"," I 'I' , '. , ',' " , ,. " , , , .... 7lc. 9 tI- ~() 31 C,..u...:.I., ~ urt v. IN THE COURT OF COMMON PLEAS DAUPlDN COUNTY, PENNSYLVANIA NO. 4/91~9r..,t CIVIL ACTION - LAW PROTECTION FROM ABUSE Julie Penney, Petitioner Raymond Lewis Boyd, Respondent NOTICE TO DEFEND YOU HAVE BEEN SUED IN COURT. If you wish to defend againBt the claims set forth in the following pages, you must appear at the hearing scheduled herein. You are warned that if you fail to do 80 the case may proceed without you and an Order may be entered against you for the relief requested in the Petition. You may lose money or property or other rights important to you. If a copy of the TEMPORARY ORDER is attached, you must obey it until the hearing. If you do not obey it, the police can arrest you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. YOU HAVE A RIGHT TO HAVE AN ATTORNEY REPRESENT YOU AT THE HEARING. 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 MAY GET LEGAL HELP. SO USTED HA SIOO DE ADO E CO TE. Si usted quiere defenderse de las reclamaciones descritas in las paginas siguientes usted debe asistir a la vista que esta citada en esta. Usted esta seindo advertido de que si falls en asistir a la vista el caBO procedera sin usted y una Orden puede ser expedida en contra suya para el remedio solicitado en la peticion. U sted puede perder dinero 0 propiedad u otros derecholl importantes para usted. Si la copia de una Orden Provisional eata ac:liunta usted debe obedecerla hasta que la vista se lleve a cabo, Si usted no la obedece la policia 10 pued~ arrestar. Usted debe llevar este documento a au abogado cnseguida. Usted tiene derecho a tener un abogado que 10 represente en la llame a la eiguiente oficina donde la informaran donde conseguir ayuda legal. Dauphin County Lawyer Referral Service 213 North Front Street Harrisburg, PA 17101 (717) 232-7536 v. IN THE COURT OF COMMON PLEAS DAUPHIN COUN1Y, PENNSYLVANIA NO. 1/q 1 JlfP'f CMLACTION. LAW PROTECTION FROM ABUSE Julie Pennay, Petitioner Raymond Lewis Boyd, Respondent fETI.TlON F9R, :eBQ1ECTlQIilRQM Al!YflE TO THE HONORABLE MOTION JUDGE: The Petition of Julie Pennay, by her attorney, Latisha K. Frederick, pursuant to the protection from Abuse Act, 23 Pa.C.S. 16701, etBeQ.. as amended, respectfully represents as follows: 1. Petitioner is an adult individual presently residing at 404 Swatara St., Dauphin, PA 17018. 2. Respondent is an adult individual residing aU04 Swatara St., Dauphin, PA 17018. 3. The relationship between Petitioner and Respondent is boyfriend and girlfriend. 4. Petitioner is not currently employed. 5. . Respondent is currently employed through JFC Temps. 6. Petitioner and Respondent have no minor children together. 7. Respondent has engaged in abusive conduct toward Petitioner as such conduct is defined in the Protection From Abuse Act. Eumples of said conduct include, but are not limited to, the following: a, On October 9, 1994 Respondent attacked Petitioner, kicked her in the head causing a concussion, tried to choke her, and prevented her from calling the police . , . b. Respondent canies a razor in his wallet and threatens Petitioner with it, while refening to the murders of Nicole Brown SimpllOn and Ron Goldman. 8. Petitioner believes that she is in immediate and present danger of further abuse and harassment from Respondent, and that she is in need of, and entitled to, protection from such abuse. WHEREFORE, pursuant to the Protection From Abuse Act, Petitioner prays your Honorable Court to: I. Immediately enter a temporary order, pursuant to Section 5(b) of the Act, 23 Fa.C,S. t6707 (B): A. Directing Respondent to refrain from approaching, abusing, harassing, or threatening Petitioner, either physically or verbally, wherever she may be; B. Prohibiting Respondent from having any contact with Petitioner, including by telephone or otherwise, except through her attorney; C. Directing Respondent to refrain from all harassing communication with Petitioner's relatives D. Directing Respondent to relinquish immediately any firearms or weapons he may own, possess, or control, to the Dauphin County SheritTupon being served herewith. II, After hearing to be held within ten days 01 the filing hereol, and pursuant to Section 1 of the Act, 23 Pa.C,S. ~708 enter a final protection order continuing the relier set forth above, for a period of one year or until the Respondent appeals this honorable court's order, whichever is earlier, and further requiring that Respondent: A. Pursuant to Section 5(d) or the Ad, 23 Pa.C.S. 16707 (D), pay all taxable costs or this action. B, Pay attorneys rees in the amount 0($250.00. ,f ., " ',.... , v. IN THE COURT OF COMMON PLEAS DAUPIDN COUN'lY, PENNSYLVANIA NO. CIVIL ACTION - LAW PROTECTION FROM ABUSE Julie Pennay, Petitioner Raymond Lewis Boyd, Rellpondent n:MPO~Y PROTECTION ORDER And now, thlll17th day of October, 1994, upon presentation and consideration oUhe within Petition, we order as follows: 1, Respondent Is prohibited from approaching, abusing, threatening, or haraBBlng Petitioner, either physically or verbally, wherever she may be. 2, Respondent is prohibited from entering or attempting to enter Petitioner's current residence or any other residence Petitioner may choose to establish. 3, Respondent is directed to refrf\in from all harassing communication with Petitioner's relatives. 4. Respondent is prohibited from contacting Petitioner in any manner, including by telephone or otherwise, except through her attorney, Latisha K. Ji'rederlck, 909 N, 2nd Street, Harrisburg, PA 17102, (717) 236-8241. 5. Respondent is directed to relinquish immediately any firearms or weapons he may own, posseRs, or control, to the Dauphin County SheritTupon being served herewith. 6, The Prothonotary, Sheriff, and local law enlorcement agencies, are directed to accept, nte and serve all copies of the Petition and Order without prepayment of COlte, 7. A certified copy of the Order shall be served on the police department(s) in thejuriadiction where Petitioner resides. Punuant to Section 7(b) of the Act, a certified copy of this Order shall immediately be filed by the police department in the county registry of protection orders. Should the police com'!! into contact with Helpondent, and should Respondent allege that he has not been served with this Order, the pollee officer shall immediately serve the Order upon Respondent. 8, Thill Order shall be enforced by a law enlorcement agency in any county where a violation occurs. As provided in Section 100c) of the Act, "[a]o arrest for violat.lon of an order Issued pursuant to this act may be without wanant upon probable cause whether or not the violation Is committed In the presence of the pollee