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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 94 - ~,;;a5" CIVIL TERM PROTECTION FROM ABUSE SALLY JANE KELLER, plaintiff BRADFORD KENT STROCK, III, Defendant TEMPORARY PROTECTIVE ORDER AND NOW, this J<I~day of October, 1994, upon pre.entation and consideration of the within petition, and upon finding that the plaintiff, SALLY JANE KELLER, now residing at 1 Timber Road, Mechanicsburg, cumberland county, Pennsylvania, is in immediate and present danger of abuse from the defendant, BRADFORD KENT STROCK, III, the following Temporary Order is entered. Tho defendant, BRADFORD KENT STROCK, III, now residing at 121 West Hain street, Shiremanstown, Cumberland County, Pennsylvania, is hereby enjoined from physically abusing the plaintiff, SALLY JANE KELLER, or placing her in fear of abuee and is ordered to stay away from the residence located at 1 Timber Road, Mechanicsburg, Cumberland County, Pennsylvania, a residence which is owned by the plaintiff's step-father. The defendant is hereby notified that if he resides in the plaintiff'S domicUe contrary to this Order, he may be in indirect criminal contempt which is punishable by a fine not to exceed $1,000.00 and/or by a sentenoe 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 nullify the provisions of the Court Order directing the detendant to refrain trom abu.ing the plaint! tt . The defendant i. ordered to retrain from having any contact with the plaintitf including, b~t not limited to, entering the plaintiff'. place of employment, harae.ing or etalking the plaintiff, and harassinq the plaintitt's relatives. Thie Order shall remain in ettect until a final order i. sntered in this caee. A hearing shall ).J<(.I'''~v the J /l<) day ot o.'alter. 1994, at NO.~ Cumberland County Courthouse, be held on this matter on f'tl]} ;r.-m. in Courtroom CarliSle, Penneylvania. The plaintift may proceed in torma DauDerie pending a further order atter the hearing. The Cumberland County Sherift's oft ice shall attempt to make service at the plaintift'e requeet, but eervice may be accompliehed under any applicable rule ot Civil Procedure. Thie Order shall be docketed in the office ot the prothonotary and forwarded to the Sheritt tor service. The Prothonotary ehall not send a copy ot this order to defendant by mai 1. The Lower Allen Township and Silver Spring Police Departmente will be provided with a copy of thie Order by attorneye for plaintift. Thie OrdMr ehall be entorced by any law enforcement agency where a viOlAtion occurs by arreet for indirect criminal contempt without warrant upon probable cauee that thie Order has been violated, whether or not the violation is co..itted in the presence of the police otficer. In the event "....-,'..1'. that an arre.t ie made under thie eection, the defendant ehall be taken without unnecem.ary delay before the Court that ieeued the Order. When that court is unavailable, the defendant ehall be taken before the appropriate dietrict juetice (23 Pa.C.S.A. Section 6113). By the Court, -U' tl/C?~;Y if (,. , J. , , h ~ .~ ., 'ill I Itl'.; R.'J'.' II', " t~rl '.. ft.\I" ";, ~"df ; ~r, ' II' . I', i' ," ,,' )-',1 ,I j-j': "I:','" '''II I, \'1,,'" " , , , 'I," " , 'I;' SALLY JANE KELLER, plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 94 - CIVIL T!RM ve. PROTICTION FROM ABUSE Br~DPORD KENT STROCK, III, Defendant NOTICE You have been sued in court. If you wish to defend again.t the claim. eet forth in the following pagee, you mu.t taxe action promptly after thie Petition, Order and Notice are .erved, by appearing personally or by attorney at the hearing scheduled by the Court and preeenting to the Court your defense. or Objection. to the claims eet forth against you. You are warned that if you fail to do eo the Court may proceed without you, and a judgment may be entered against you by the Court without further notice for any money claimed in the Petition or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICI SET fORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. COURT ADMINISTRATOR, 4th FLOOR CUMBERLAND COUNTY COURTHOUSE CARLISLE, PENNSYLVANIA 17013 TELEPHONE NUMBER: (717) 240-6200 SALLY JANE KELLER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 94 - CIVIL TERM ve. PROTECTION FROM ABUSE BRADFORD KENT STROCK, III, D~fendant EE11TION FOR PROTECTIVE ORDER RELIEF UNDER THE PROTECTION FROM ABUSE ACT 23 P.S. SECTION 6101 A. ABUSE 1. The plainti,ff is an adult individual whose permanent addrees ie 1 Timber Road, Mechanicsburg, Cumberland county, Penneylvania, 17055. 2. The defendant is an adult individual residing at 121 Weet Main street, Mechanicsburg, Cumberland County, Pennsylvania, 17055. 3. The defendant is the plaintiff's former intimate partner. 4. Since approximately May 1994, the defendant hae attempted to cause and has intentionally, knowingly, or recklessly caueed bodily injury to the plaintiff, and by phyeical menace hae placed the plaintiff in fear of imminent serioue bodily injury. This has included but ia not limited to the follOWing epecific instances of abuse: a. On or about October 8, 1994, the plaintiff came out of a gae station to find the defe~dant coming t~warde her, ecreaming. The plaintiff turned to walk away and the defendant grabbed the pleintiff who is 6 1/2 months pregnant by the arm and prevented her from leaving. A etation attendant yelled at the dafendant and he got in his cer end left. The plaintiff feele that further abuse might have taken place if the station attendant had not been there. The plaintiff, since this incident, receivee approximately two hang-up calls per day. b. In or around July 1994, the defendant mad. threats to the plaintiff that he would kidnap her until the baby wae born and have her taken care of because his ,family doesn't get it. hande dirty, causing the plaintiff to fear for her safety. c. In or around Hay and June 1994, approximately evsry few daye, the defendant was physically abusive toward the plaintiff in ways inClUding, but not limited to the following: putting pillowe over the plaintiff's face until she almost passed out, grabbing her by the neck and holding her against a wall, grabbing the plaintiff by the wriste and reetraining her from leaving, biting the plaintiff, Choking the plaintiff, poking the plaintiff in her cheet, dragging the plaintiff through the yard, and pushing the plaintiff. d. On or about May 27, 1994, while the plaintiff and defendant were watching television with the plaintiff's step- sieter and friend, the defendant ripped the plaintiff's nightgown off of her. The plaintiff, in an attempt to cover herself, wrapped a blanket around her. The defendant grabbed the bottom of the blanket, pulled the plaintiff off of the couch, drAgged her through the living room, kitchen, and back porch, and atte.pted to push her outside. The defendant then told the plaintiff to put her nightgown on and th.y went back to the (louch. The defendant then demanded in front of everyona that thsy have sex. When the plaintiff refu.ed, she got up to walk away and the defendant grabbed the plaintiff by the ankles, caueing her to fall onto her etomach. The defendant then laid on top of the plaintiff'S back. grabbed the plaintiff by the hair, jerking her head backward, and told her to shut-uP. The defendant then pushed the plaintiff's head to the floor, raised the plaintiff'S nightgown, and forced th. plaintiff to submit to anal intercourse. The defendant told the plaintiff to stop etruggling or it would hurt worse. 5. The plaintiff believes and therefore avers that ehe will be in immediate and present danger of abuse from the defendant, and that ehe 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. ATTORNEY FEES 7. The plaintiff asks for attorney feee to be paid to Legal Servicee, Inc. pursuant to the Protection from Abuse Act. ~ I ST~TUS TO PROCEED IN FORMA PAUPERIS 8. The plaintiff is unaware if the defendant ie employed. 9. The plaintiff currently receive. $5.00 per hour working approximately twenty hour. per Week. 10. The plaintiff doe. not have funde available to pay the feee for filing and eervice. WHIREFORE, pursuant to the prov1eione of the "Protection from Abuee Act" of October 7, 1976, 23 P.S. Section 6101 At aaq., ae amended, the plaintiff praye thie Honorable Court to grant the fOllowing relief: A. Grant a Temporary Order pureuant to the "Protection from Abuse Act:" 1. Requiring the defendant to refrain from abueing the plaintiff or placinq her in fear of abu.e. 2. Requiring the defendant to refrain from haVing any contact with the plaintiff, inClUding, but not limited to, entering the plaintiff's place of employment, from haraeeing or etalking the plaintiff, and haraesing the plaintiff'e relativee. 3. Ordering the defendant to stay away from the residence located at 1 Timber Road, Mechanic.burg, PennSYlvania, which the part i.. have never .hared. 4. Ordering the defendant to .tay away from any reeidence the plaintiff may in the future eetablieh for hereal f . 8. Schedule a hearing in accordance with the provieione of the "Protection from Abuse Act," and, after such hearing, enter an order to be in effect for a periOd of one year: I. Requiring the defendant to retrain from abueing the plaintiff or placing her in tear of abu.e. 2. Requiring the detendant to retrain trom having any contact with the plaintiff, including, but not limited to, reetraining the defendant trom entering the plaintift's place ot employment, hara.eing or .talking the plaintift, and harasaing the plaintitt'e relativee. 3. Ordering the detendant to etay away from the reeidence located at 1 Timber Road, Mechaniceburg, Pennsylvania, which the parties have neV1r shared. 4. Ordering the defendant to stay away from any re.idence the plaintitt may in the tuture establish for hereelf. 5. ordering the defendant to pay attorney fe.. to Legal Services, Inc. pureuant to the Prot~ction From Abuee Act. The plaintiff further aeks that this Petition be filed and .erved without payment of coets, pending a further order at the hearing, and that a copy of this Petition and Order be d.~ivered to the Lower Allen Townehip and Silver Spring Township Police Departments as the Police Departm~nts with jurisdiction to enforce this Order. . "'.,. ", d' , . h ,11,'_"r.",o....'_"...",,' The plaintiff praye for euch other relief a. may be juet and proper. Reepectfully eubmitted, I, ~r:~.d Joan C ey Philip c. Briqanti Attorneys for Plaintiff LEGAL SIRVICES, INC. a Irvine Row Carli.la, PA 17013 (717) 243-9400 , I " '\,j-., H,'/h' ~~;'_. :;1 I 1(:.' ii,I,',";'!, , 'I II:'! I. r' ll,;:', !';"i,i-, !;./"'I,I 1'1,', ' :i:(;,"),I, t' , 11'liil:!, !'" ;'i ,.\'1,', i:\;;~':' !),!,tr't, ;:i,,,", '1'1:',1,' 'i", ~ I ' "~'I I:;) b:"}' "'-, , 'II , :"1_\." ,1"" , V:h(I,;' , It\l,,'" I," :1/." 1"\" ,'1<,' I,' ',"; j' ,i,i"I,: ~:'.' ,i', ' to ,~': ,'- 'II') , \\1:; ;)11.', j:;'ll';' The above-named Plaintiff, Sally J. Keller, verifiea that the etatementa made in the above Petition are true and correct. Plaintiff understand. that false etatements herein are made aUbject to the penalties of 18 Pa. C.S. 14904, relating to unaworn falsifi~ation to authorities, Date: /o/-9J-I2-'I- ,./,~ ~ lfally . eller, P aintiff , " , \ I" " ,Ii ." , , " , , " , ", , " "~I , I"~ , " I,I} ,';JI' , , , , ,'P. , , , " , , , , , i " ,( , , ,',' .', , '. , , , " I , " " j" a) " 'At, , " " , , , , ,', , " ,', " , " " , " SHERlF'F"S RE'lVRN ~'I1l OF PftlSYLVANlA, c::ootfI"{ OF CLMBERLIIW In The Court of Common Pleas of Cumberland County, Pennsylvania No. 94-6125 Civil Term Temporary Protective Order Protection From Abuse Notice and Petition for Protective Order Sally Jane Keller VS Bradford Kent Strouck, III Wesley Cook ,X~lfdlr. Deputy Sheriff of CUrtlerland County, Pennsylvania, who being duly swom lICcording to law, says, Temporary Protective Order Protection From Abuse that he served the wi thinNo t ice and Petition for Protective Order upon Bradford Kent Strouck, III . , the defendant, at 6:05 day of October . 19.2.!. at o'clock P .M. I:ln I EDST, on the 26 121 West Main Street, Shiremanstown , Cl.rnberland County, PelUlsylvania, by handing to Bradford Kent Strouck, III ~ Temporary Protective Order Protection From Abuse a tnJe and attested copy of theNotice and Petition for Protective Order and at the sare time directing hill attention to the contents thereof. and the "Notice to Plead" endorsed thereon. Sheriff's Costs. Docketing Service Affidavit Surcharge 14.00 6.16 20.16 So answers I r~n-..~< -r'~.4? R. Thanas Kline, Sheriff Swom aM subscribed to before 11\9 by L/k' ,Y ~-t_ Depu~;riff this -1~___ day of 'l1J.u.< 'L~"- 19_'€2- A.D. ~ r1 )l4~...~ Prothonotary SALLY JANE KELLER, Plaint iff vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 94 - I.. I~!i CIVIL TERM PROTECTION FROM ABUSE BRADFORD KENT STROCK, III, De fendan t PROTECTIVE ORDER AND NOW, this ~ day of October, 1994, upon consideration of the Consent Agreement of the parties, the followinl Order is entered: 1. The de fendan t. BRADFORD KENT STROCK, II I, is en j 0 i ned from physicallY abusing the plaintiff,' SALLY JANE KELLER, or from placinl her in fear of abuse. 2. The defendant. BRADFORD KENT STROCK, III, is enjoined from havinl any contact wi th the plaint iff, including but not limited to, entering the plaintiff's place of employment, harasslnl or stalking the plaintiff, and harassing the plaintiff's relatives. 3. The defendant, BRADFORD KENT STROCK, III, is hereby ordered to stay away from the residence located at 1 Timber Road, Nechanicsburg, Pennsylvania, and from any other residence that she may establish for herself in the future. The defendant is hereby notified that if he goes to the plaintiff's domicile contrary to this Order, he may be In indirect 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 or co-residence on the part of the plaintiff and defendant shall not nullify the provisions of the court order directing the defendant to refrain from abusing ths plaintiff. 4. This Order shall remain in effect for a p~riod of one year. ,. The Lower Allen and Silver Spring 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 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 taken without unnecessary delay before the Court that issued the Order. When that Court is unavailable, the defendant shall be taken before th~ appropriate district justice (23 PS Section 6113). By the Court J '" Maw Z 8 lf7 AIf '9~ '\, diFICf Of r"f,' 'rHONQTMI~ CUiI41!tNLAt/C COUNTY PEHNSYlV~H" , I " " :. '/ " I II .<1 \1 " , " " , " I' : " ,,:1 '. " Jl.'J 'Il! ". ')\1' ~fh " ~(: ' ;1:111'1 ':"1', "L:ii ~,J . ij" I'~t I; Vii,. ,,',' '~';i ,.. \' i, i};"i! 1:[,;:''','' r:'~:,;J ?}ij" ':i,', I)i: , " " " >'1 ' , , I, " vs. IN TilE COURT OF COMMON PLEAS OF CUMBERI,AND COUNTY. PENNSYLVANIA CIVIL ACTION - LAW NO. 94 - ,-':lS CIVIL TERM :. PROTECTION FROM ABUSE SALLY JANE KELLER, Plaint iff BRADFORD KENT STROCK, III. Defendant CONSENT AGREEMENT This Agreement is entered on this ~ day of October, 1994. by the Plaintiff, SALLY JANE KELLER, and the defendant, BRADFORD KENT STROCK, III. 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 alree that the following may be entered as an Order of Court. 1. The defendant, BRADFORD KENT STROCK, agrees to refrain from abusing the plaintiff, SALLY JANE KELLER, 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. J. 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 located at I Timber Road, Mechanicsburg, Pennsylvania. S. The defendant agrees to stay away from any residence the Plaint iff IIISY establ j"h for herself in the future. 6. The defendant, although entering into this Agreement, does not admit the allegatio~s made in this Petition. 7. The defendant understands that the Protective Order entered In this matter shall be In effect for a period of one year. 8. The defendant understands that this Order will be enforceable In the same manner as the Court's prior Temporary Protective Order entered In this case. WHEREFORE, the parties request that an Order of Court be entered to reflect the above terms. Sail Keller, Plaintiff ~~~ Carey hilip C. Briganti Attorneys for Plai iff LEGAL SERVICES, INC. 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 Bradfor NBV z 8 111 A1119~ " '" ,,' OFFICE Of "rl'IOH,)iA~Y I~VHLl'F,,'hL' CCUtHY P[:,N~li;I~HI4 ,:\ " @ " , " ;', \ I , ,