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Kamila J. Scaruzzo,
Plaintiff
v.
I IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY. PENNSYLVANIA
NO. 915- &H" CIVIL TERM
PROTECTION FROM ABUSE
Chri.topher J. LaRocca,
Defendant
AND NOW, th is
IiHfgfJAJj'Lf!BQill.TIOH .onDER
.. .'l~~. day of February, 1995, upon
pr~sentation snd consideration of the within Petition, and upon
finding that the plaintiff, Kamila J. Scaruzzo, now residing at
an undisclosed location is in immediate and present danger of
,
abuse from the defendant, Christopher J. LaRocca, the following
Temporary Order is entered. Law enforcement agencies, human
eervico 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 Qemographic
information about the plaintiff except by furthsr Order of Court.
The defendant, Christopher J. LaRocca, (SSN: 168-154-615715
and Date of Birth: July 12, 1960) now residing at 50 Canal
Street, Middletown, Oauphin County, Pennsylvania, is hereby
enjoined from physically abusing the plaintiff, Kamila J.
Scaruzzo, or plaCing her in fear of abuse.
i,
j,
,
The defendant is ordered to stay away from the plaintiff's
residence, a residence to Which the plaintiff moved to avoid
abuse and which is not owned or leased by the defendant.
The defendant is ordered to refrain from having any direct
or indirect contact with the plaintiff inclUding, but not. limjted
to, telephone and written communications.
The defendant is enjoined from harassing and stalking the
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plaintiff.
A violation of this Order may eUbJect the defendant tOt i)
arreat under 23 Pa. c.a. 10113; ii) a private criminal complaint
under 23 Pa. C.B. 10113.1; iii) a charge of indirect criminal
contampt under 23 Pa. C.B. 10114, puniahable by impri80nment up
to eix months and a fine of tl00.00-tl,000.00; and Iv) civil
contempt under 23 Pa. C.B. 10114.1. Resumption of co-residance
on tha part of the plaintiff and defendant shall not nullify the
proviaione of the court order.
This Order shall remain in effect until modified or
terminated by the Court after notice 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.
Thie Order Ihall remain in effect until modified or
terminated by the Court after notice or hearing and, can b.
~xtended 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
terminated by the court after notice or hearing. A hearing shall
be held on this matter on the li:._U~::_. day of February, 1998, at
~_:~__'L. m. , in Courtroom No ..f::, CUnlber ll'lnd County Courthouse.
Carliele, Pennsylvania.
The plaintiff may proceed without pre-payment of feel
pending a further order after the hearing.
The Cumberland County Sheriff's Department ahall attempt to
make service at the plainti'f's r8q~e8t a~d without pre-payment
of feea, b~t saryice may be accomplished under any applicable
rule of Ciyil Procedure.
This Order Ihall be docketed in the office of the
Prothonotary and forwarded to the Sheriff for aerYica. The
Prothonotary ahall not 'end a copy of this Order to the defendant
by ma i I .
The appropriate police departments will bs proYided with.
certified copy of this Order by the plaintiff's attorney. Thia
Order ehall be enforced by any law enforcement agency where a
yiolation occurs by arrest for indirect criminal contempt without
warrant upon probable cau.e that this Order ha. been Yiolated,
whether or not the violation i. committed in the prllence of the
police officer. In the eyent that an arr.,t is madl, under thie
slction, the defendant shall be taken without unnecelsary delay
before the court that ie.ued the order. When that court ia
unavailable, t,he defendant shall be taken bafore the appropriate
diatrict JusticI. (23 P.S. . 6113).
By the Court,
~ t:
I . "
,-- \ J ~k'r/-'"
JUd9IU-~ ..
Kamila J. Scaruzzo,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
ohrtetopher J. LaRooca,
Defendant
NO. 95-
CIVIL TERM
PROTECTION FROM ABUSE
NOTICE
You have been sued In court. If you wish to defend againat
the claims set forth in the following pages, you must take action
promptly after this Petition, Order and Notice are served, by
appearing personally or by attorney at the hearing scheduled by
the Court and presenting to the Court your defenses or objections
to the claims set forth against you. You are warned that if you
fa 11 to do so the Court may procesd 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.
Efi..lLAtiQ~Qlli
If the case goes to hearing and the jUdge grants a
Protection Order, a aurcharge of $25.00 will be asselled againet
you. You may also be required to pay attorney fee. to Legal
Services, Inc. for their representation of the plaintiff.
You 8hould take this paper to your lawyer at once. 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 cen get legal help.
COURT ADMINISTRATOR, 4th FLOOR
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PENNSYLVANIA 17013
TELEPHONE NUMBER: (717) 240-6200
Kamila J. Scaruzzo,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY. PENNSYLVANIA
v.
NO. 96-
CIVIL TERM
Chri.topher J. LaRocca,
D.fendant
PROTECTION FROM ABUSE
Eli I T IOtiE.oJLP..B.OIiQ.Il.otL.QflDiB
RELIEF ONDER THE PROTECTION FROM ABOSE
ACT, 23 P.S. . 0101 et ..q.
A-,_~BlJU
1. The plaintiff, Kamila J. Scaruzzo, is an adult
individual whose permanent residence was 60 Canal Street,
Middletown, Dauphin County, Pennsylvania.
2. The plaintiff is temporarily staying at an undisclos.d
location for hsr own protection and to avoid further abuee ae ie
more fully set forth herein. This address will be furnished to
the court upon requeet.
3. The defendant, Chr i stopher J. LaRocca, (SSN: 108-54-
6575) (Date of Birth: July 12, 1960), ie an adult individual
reeiding at 50 Canal Street, Middletown, Dauphin County,
Penneylvania.
4. The defendant has had an intimate relationship with the
plaintiff.
5. Since approximately December 1994, the defendant hae
attempted to cause and has intentionally, knOWingly, or
recklessly caused bOdily injury to the plaintiff, has placed the
plaintiff in reasonable fsar of imminent serioue bOdily injury
and has knowingly engaged in a course of conduct or repeatedly
committsd acts toward the plaintiff under circumetances which
placed the plalntl'f In reasonable 'ear 0' bodily Injury. Thle
has Inoluded, but Is not limited to, the following spect'lc
Inetancel of abuse:
a. On or about January 31, 199&, the de'endant
grabbed the plalntlff'l arm and 'oroefully shoved her
against a brick wall causing her to fear for her
eafety. The police were called to the scene and they
oharged the defendant with dleorderly conduct and
escorted the plaintiff to a safe place.
b. In or about the last week In January 199&, the
defendant grabbed the plalntl'f's wrist and twllt.d her
arm behind her back threatening to break her arm. The
defendant then grabbed the plaintiff by the hair and
continued to threaten her.
c. Since approximately Oecember 1994, the de'endant
has on several different occasions, pushed the
plalntl'f, twleted her arm, pulled her hair, and
threatened to kill her and her mother.
e. On or about January 31, 199&, the plalntl" le,t her
r.eldence at 50 Canal Strest, Middletown, Oauphln County,
Pennsylvania, In order to avoid 'urther abuse.
7. The plalntlf' believes and there'ore avere that Ihe 1.
In Immediate and present danger of ~buse 'rom the de,.nd.nt and
that ahe la In need of protection from such abuse.
8. The plaintiff desires that the de'endant be prohlblt.d
from having any direct or Indlreot contact with the plalntlf'
2
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including, but not limited to, telephone and written
communications.
9. The plainti'f desires that the defendant be enjoined
'rom harassing and stalking the plainti'f.
D.,---~LU8IVE "po8SE88lOt:f
10. The plainti'f cannot reveal the namss 0' the owners 0'
the home because the names will disclose her whereabouts which
must be kept confidential for her protection. The plaintif' is
not seeking the eviction 0' the de'endant from his residence.
11. The plaintiff desiree that the defendant be ordered to
stay away from the plaintiff's residence.
C...__.HIOBtiELEE.E.G
12. The plainti" asks that the defendant be ordered to pay
reasonable attorney 'ees to Legal Services, Inc.
WHEREFORE, pursuant to the provisions of the "Protection
'rom Abus. Act" of October 7, 1976, 23 P.S. . 6101 J.t J.I.ll.. as
amended, the plaintiff prays this Honorable Court to grant the
'ollowing relief:
A. Grant a Temporary Order pursuant to the
"protection from Abuse Act:"
1. Ordering the defendant to refrain from
abusing the plaintiff or placing her in 'ear 0'
abuse.
2. Ordering the defendant to refrain from haVing
any direct or indirect contact with the plainti',
inclUding, but not limited to, telephone and
3
wr1tten communication8.
3. Ordering the defendant to refrain from
hara88ing and stalking the plaintiff.
4. Order1ng the defendant. to stay away from the
plaintiff'. re.idence which the partie. have never
.hared.
15. Order1ng the defendant to stllY away from any
res1dence the plaintiff may In the future
eetablish for herself.
B. Schedule a hearing 1n accordance with the provl,ions of
tho .Protect10n from Abu.e Act,. and, after Buch hearing, enter
an order to be in effect for a period of one year:
1. Ordering the defendant to r.fraln from
abusing the plaintiff or placing her In fear of
abule.
2. Order1ng the defendant to r.frllln from having
any d1rect or Indirect contact with the plaintiff
1ncluding, but /lot, lImited to, telaphona Ind
written communications.
3. Ordering the defendant to rafrlin from
hlrassing and stalkln~ the plaintiff.
4. Ordering the defendant to stay away from the
pllintiff's reAldenc8 which the plrtlea have never
.hared.
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15. Ordering the def,ndant to stay aWIY from any
re.idence the plalntl'f may in the future
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INSTRUCTIONS TO THE DEFENDANT
-.~'.__.,-_._..._---................_.-_.- _..__._n_'_.__...________".__...... ._.~___ _..__ ._"' _,__,_"__0"______.
A~ you know, th~ plnlnllff hns filed n I~/llll ncli'HI Il/lninst you undur thu Protection
Prom Ahusu Act Ilnd hils ohtlllnud II Tumpomry PmlectJon nrder, The plllintlff is prllpnrll,l
to have II tllmrlnll held In order to ohtllin (\ finnl Prote,:tJon Ordur effective for <lIIe (I) year.
All nn /lIternlltive, you mllY conllent to the enlry of the flnlll Protection Ordur to be In
effect for one YUill'. If you Ilrc wilHng to conllent you Ilhould clllI l.llll/ll lIervlcf,lll, Inc. In
Carlisle lit 24J-'l400, 766-8475 fnlm the Wellt IIhorll "I' 530-5866 fftlm IIhl(l(lIl/lllhurg, and Bilk
to Ilpllllk to the Ilt/lff person handling the CIIIlIl Bboul /l Cl)Osent Agrcllment.
The Cnnsent Al1lreu/IIent should be prellnrml hefol'l) the time schoclulell for the hearing
110 the Court will know Ilhend of time thllt tho caso will nllt ho C'H1t~Rtl'd, In .';om~ CURes,
rUllardlesR IIf whether n settlement hy Consent Agreemonl hilS hoon rellched, th~ pllnleR
mUllt appellI' in court .1t thu time scheduled fill' hellrlng. If tht! clIse is uncllnlusted, the
court nppenmnce wllJ he hrief, The juclgu will mqku Ilure lhu pllrtlus llndul'stllnd thu
Consent Agreement lind fin/II Protection Order,
If you do not Ilgree to the entry of tht! finnl lll'otedion Order, .1 conteslClI he/\rtnll will
take plnct! I\t tht! ,~chedulucl time. When /I flnnl Protedl'1TI l)rdt!r 11'1 untt!red. it will hv sent or
given tn you, the pl/lIntlff, nnd the /IPPl'oprinte pollcu dllpnrtnlOnts. If you fnll to Ilhhh. hy
the terms <If tht! rlnlll Protection Ol'llt!r you will he ~llhj<Jct tn Immedlnte nrrt!st, I\nd II rlnt! of
$\00,00 to .~l,OOO,OO lind/or n j/III sentence IIf up to six IIJI1IlthH .Itlll ('ther relief.
f1ill1U\NIL CJ}U!i.
If the cnse goes tn henrinll 111I<1 the JUdgt! !lJ'llnts n Prott!ctton Ol'clt!r. II surchllrllll 11f
.'25.00 will 1)(' IIBHUS.Hed I\gllln.,t YIIU, YIIU may ,Iho he requlrud to PIlY IIttornt!Y fecR to Legal
/lel'vlces, Inc. for lhell' l'e!lI't!serltlltlon nf the lJllIllIllff,
Vou IIIlOUW TAKI': TIIlII PAJlI\R TO VOUR LAWVfo:R AT ONCE. II' YOll no NOT IlAVP. A
l.AWYER OR CANNOT A"'FORIl ON I';, no TO OR Tl~I.J~PIlc)Nf: TlIf: OFFICI'; IIE'I' FORTII IIEI.OW TO
PIND OUT WlmRI~ VOl] CAN emT l.EnAl. 1IF.l.Jl.
e'otJRT ADMINl RTRATOR, ~t.h I'l.llnR
CIJMI\J~Jn,ANn COl1NTY ('OIIHTIICll1SE
C"'~I,JRr.E. PF,NNSYI.VANI,I 1701.1
THEPIIONE flllMJ\Jo:JH (717) HO-1>20C)
v.
IN THE COVRT OF COMMON PLHAS OF
CVMBERLAND COVNTY, PENNSYLVANIA
NO. 915- ~ ~:, CIVI L TERM
PROTECTION FROM ABVSE
Kamila J. Scaruzzo,
Plaintiff
Ohriltopher J. LaRocca,
Defendant
TEMPQ~ARY PROTECTION ORQEB
7'1;
NOW, this. ? day of February, 1996, upon
AND
presentation and conlideration of the within Petition, and upon
finding that the plaintiff, Kamila J. Scaruzzo, now residing at
an undisclosed location ie in immediate and present danger of
abuse from the defendant, Christopher J. LaRocca, the follOWing
Temporary Order is entered. Law enforcement agencies, human
.ervice agencies and school districts .hall not dilclose the
presence of the plaintiff in the juri.diction or diltrict or
furnieh any addre.., telephone number, or any other demographic
information about the plaintiff except by further Order of Court.
The defendant, Christopher J. LaRocca, (SSN: 168-154-615715
and Date of Birth: July 12, 1960) now residing at 150 Canal
Street, Middletown, Dauphin County, Pennsylvania, is hereby
enjoined from phy.ically abusing the plaintiff, Kamila J.
Scaruzzo, or placing her in f9ar of abuse.
The defendant is ordered to etay away from the plaintiff"
residence, a residence to which the plaintiff moved to avoid
abuse and which is not owned or leased by the defendant.
The defendant is ordered to refrain from having any direct
or indirect contact with the plaintiff inclUding, but not limited
to, telephone and written communicatione.
The defendant i' enjoined from harae,ing and Italking the
plaintiff.
A violation of this Order may eUbject the defendant to: i)
arreat under 23 Pa. C.8. 10113; ii) a privata criminal complaint
under 23 Pa. C.8. 10113.1; iii) a charge of indirect criminal
contempt under 23 Pa. C.8. 10114, puniahable by impriaonment up
to eix mQnths and a fine of "00.00-",000.00; and iv) civil
contempt under 23 Pa. C.8. 10114.1. Resumption of co-residence
on the part of the plaintiff and defendant ahall not nullify the
provisiona 0' the court order.
This Order ahall remain in e'fect until modi'ied or
terminated by the Court a,ter notice or hearing and, can be
extended beyond that time, if the Court 'inds that the defendant
ha. committed another act of abuse or hae engaged in a pattern or
practice that Indicates continued riak of harm to the plaintiff,
This Order shall remain in effect until modified or
terminated by the Court after notice or hearing and, can be
extended beyond that time, if the Court finde that the defendant
has committed another act of abu.e or ha. engag.d in a pattern or
Practice that indicatel continued riak of harM to the plaintiff.
Thie Order shall rsmain in effect until modified or
terminated by the court after notice or hearing. A hearing shall
ffi
be held on thie matter on the ~~ day of February, 199&, at
1~'~cl(~m., In Courtroom No.~, Cumberland County Courthouse,
carliele, Pennsylvania.
The plaintiff may proceed without pre-payment 0' f.es
pending a further order a'ter the hearing.
The Cumberland county Sheri'f's Department eh.ll attempt to
make ssrvice at the plaintiff'l request and without pre-payment
01 fees, but service may be accomplished under any applicable
rule of Civil Procedure.
This Order Ihall be docketed in the office of the
Prothonotary and forwarded to the Sheriff for service. The
Prothonotary shall not lend a copy of this Order to the defendant
by mail.
The appropriate police departments will be provided with a
oertified eopy of thil Order by the plaintiff's attorney. Thil
Order shall be enforced by any law enforcement agency where a
violation occurs by arrelt for indirect criminal contempt without
warrant upon probable caule that this Order hae been violated,
whether or not the violation is committed in the pre.enee of the
police officer. In the event that an arrest is made, under thil
.ection, the defendant Ihall be taken without unneceslary delay
before the court that iSlued the order. When that court il
unavailable, the defendant ahall be taken before tha appropriate
district JUltice. (23 P.S. . 8113).
By the Court,
Ld /{/ .!tt,6.~/ de6<.... .jrv
Judge /
lit I""E COPY "ROM RECORD
IIId :-tit, ,lltrt UIlII. "'_.
CI_, ,.. _
-~ 1 t.f.l....
Kamila J. Scaruzzo,
Plaintiff
v.
IN ntE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, P~NNSYLVANIA
NO. 95-(."':" CIVIL TERM
PROTECTION FROM ABUSE
Chri.topher J. LaRocca,
Defendant
NOTICE
You have been sued in court. If you wi.h to defend again.t
the claims set forth in the folloWing pages, you must take action
promptly after thie Petition, Order and Notice are ..rved, by
appearing personally or by attorney at the hearing .chedu1ed by
the Court and pre.enting to the Court your d.f.n.e. or objection.
to the claims set forth against you. You are warn.d that if you
fail to do so the Court may proc..d without you, and a judgment
may be entered again.t you by the Court without further notic.
for any money claimed in the Petition or for any other claim or
r.1ief requested by the plaintiff. You may lose mon.y or
property or other rights important to you.
FEES AND COSTB
If the case goes to hearing and the judge grant. a
Prot.ction Order, a surcharge of t25.00 will be a......d again.t
you. You may also be required to pay attorn.y fee. to Legal
,
Services, Inc. for their representation of the plaintiff.
You ehould take thie peper to your lawyer at once. If you
do not have a lawyer or cannot afford one, go to or telephone the
office Bet forth below to find out where you can get legal hvlp.
COURT ADMINISTRATOR, 4th FLOOR
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PENNSYLVANIA 17013
TELEPHONE NUMBER: (717) 240-8200
Kamila J. Scaruzzo,
Pl.intiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 1)5-
CIVIL TERM
Ohristopher J. LaRocca,
Defendant
PROTECTION FROM ABUSE
EiI~ FOR PROTECTION ORDER
RELIEF UNDER THE PROTECTION FROM ABUBE
ACT, 23 P.S. . 5101 at .eq.
~
1. The plaintiff, Kamil. J. Scaruzzo, is an adult
individual whose permanent residence was 50 Canal Street,
Middletown, Dauphin county, Pennsylvania.
2. The plaintiff ie temporarily staying at an undisclo.ed
location for her own protection and to avoid further abuss a. i.
more fully $et forth herein. Thil address wjll be furnished to
the court upon reque.t.
3. The defendant, Chrietopher J. LaRocca, (SSN: 18B-54-
5575) (Date of Birthc July 12, 1960), is an adult individual
re.iding .t 50 C.n.' Street, Middletown, Dauphin County,
Pennsylvania.
4. The defendant hae had an intimate relationship with the
plaintiff.
5. Since approximately December 1994, the defendant has
attempted to cause and has intentionally, knOWingly, or
recklessly caused bodily injury to the plaintiff, has placed the
plaintiff in reasonable fear of imminent serious bodily injury
and has knowingly engaged in a course of conduct or repeatedly
committed acts toward the plaintiff under circumetances which
placed the plaintiff in reasonable fear of bodily injury. Thie
has included, but is not limited to. the following epecific
instances of abuse:
a. On or about January 31, 199~, the defendant
grabbed the plaintiff'e arm and forcefully Ihoved her
against a brick wall cauling her to fear for her
safety. The police were called to the scene and they
Charged the defendant with disorderly conduct end
escorted the plaintiff to a safe place.
b. In or about the last week in January 199~, the
defendant grabbed the plaintiff's wriet and twisted her
arm behind her back threatening to break her arm. The
defendant then grabbed the plaintiff by the hair and
continued to threaten her.
c. Since approximately December 1994. the defendant
has on leveral different occasionl, pUShed the
plaintiff, twieted her arm, pulled her hair, and
threatened to kill her and her mother.
8. On or about .'anuary 31, 199~, the plaintiff left her
reeidence at ~o Canal Street, Middletown, Dauphin County,
Pennsylvania, in order to avoid further abuae.
7. The plaintiff believes and therefore avers that Ihe ia
in immediate and preeent danger of abuae from the defendant and
that she is in need of protection from such abuse.
8. The plaintiff desire. that the defendant be prohlbit.d
from having any direct or indirect contact with the plaintiff
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including. but not limltod to, telephone ~nd written
qQmmunicationl.
9. The plaintiff desireo that the defendant be enjoined
'rom harassing and etalking the plaintlff.
B. EXCLU8JVE POS~ESSIO~
10. The plaintif' cannot reveal the names of the owner. Qf
the home because the names will diaclose hor whereabouts which
muat be kept confidentlal for her protection. The plaintiff la
not .eeking the eviction of the defendant from hls resirlence.
II. The plaintiif desires that the defendant be ordered to
.tay away from the plaintiff'l residence.
C. ATTORNEY FEES
12. The plaintlff aeke that the defendant be ordered to pay
reaaonable attorney feee to Legal Services, Inc.
WHEREFORE, pursuant to the provisiona of the "Protection
from Abu.. Act" of October 7, 1978, 23 P.S. . 8101 J..t IJ.Q., ..
amended, the plaintiff praye this Honorable Court to grant the
fOllowlng relief:
A. Grant a Temporary Order purauant to the
"Protection from Abuae Act:"
1. Ordering the defendant to refrain from
abuaing the plaintiff or placing her in fear 0'
abuse.
2. Ordering the defendant to refrain from having
any direct or indirect contact with the plainti"
inclUding, but not limited to, telephone and
','
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writ.ten communications.
3. Ordering the defendant to refrain from
haralsing and stalking the plaintiff.
4. Ordering the defendant to .tay away from thl
plaintiff's reeidence which the partie. havI nevlr
shared.
5. Ordering the defendant to stay away from any
residence the plaintiff 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 ordsr to be in effect for a periOd of one year:
1. Ordering the defendant to refrain from
abusing the plaintiff or placing her in fear of
abu.e.
2. Ordering the defendant to refrain from having
any direct or indirect contact with the plaintiff
inclUding, but not limited to, t4lephone and
written commu~ication..
3. Ordering the defendant to refrain from
harassing a~d stalking the plaintiff.
4, Ordering the defendant to stay away from the
plaintiff's residsnce which the partiee have never
shared.
5. Ordering the defendant to stay away from any
residence the plaintiff may in the future
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