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7lc. 9 tI- ~() 31 C,..u...:.I., ~
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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