HomeMy WebLinkAbout95-01199
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REBECCA], MITCHELL
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: CIVIL ACTION - LAW
: PROTECTION FROM ABUSE.
CHARLES W, MITCHELL,
Defendant
; NO, 95- II '1 ~I CIVIL TERM
PETITION FOR TEMPORARY PROTECTIVE ORDER
The petition of Rebecca ], Mitchell represents as follows:
COUNT I - PROTECTION FROM ABUSE
1. Plaintiff is an adult individual who is resides at the Harvon Motel, 851 N,
Hanover Street, Carlisle, Cumberland County. PeMsylvania, Plaintiff brings this action for
herself.
2, Defendant is an adult individual who is residing at 430 Pine Dale Road, Carlisle,
Cumberland County, PeMsylvania,
3, Plaintiff and Defendant were married, but were divorced April 19, 1994,
4, Over the course of their relationship, Defendant has allempted to cause and has
intentionally, knowingly, and recklessly caused bodily injury to Plaintiff, Defendant has
attempted to harass and has harassed the Plaintiff, Through his actions, the Defendant has
placed the Plaintiff in reasonable fear of imminent serious bodily injury, This has included but
is not limited to the following instances of abuse,
5, On March 2. 1995, Defendant accosted the Plaintiff at Dolly's Laundramat on
Carlisle Pike, Carlisle. Cumberland County. Pennsylvania, At that time, he yel,led at her stating
"You're going to get what you deserve" and "I'm not going to leave you alone, That's final."
The Plaintiff did not call the police,
6, On March 1, 1995. Defendant twice called the Harvon Hotel where Plaintiff is
slaying to harass her, On both instances he accused her of owing him money and demanded that
she pay him, Plaintiff denies owing the Defendant any money, She asked the Defendant to stop
harassing her and hung up the phone, Plaintiff did not contact the police,
7, On February 27, 1995, Defendant accosted the Plaintiff at Nell's Grocery Store
on Spring Road, Carlisle, Cumberland County, Carlisle, He followed the Plaintiff and her
boyfriend up and down the aisles of the grocery store, When she attempted to leave the store.
he attempted to make her stop, When she refused to stop, he yelled profanities at her and
caused a scene, The Plaintiff did not call the police,
8, Later that same day, February 27, 1995, Defendant physical,ly assaulted the
Plaintiff at the Nell's Grocery Store on Walnut Bottom Road, Carlisle. Cumberland County,
Pennsylvania, On this instance, he waited for the Plaintiff to exit the grocery store and
approached her while she was in the parking lot. He first grabbed her wrists, He released the
wrists and then grabbed her foreanns leaving bruises on the inside uf both anns where he had
tighteded the grip of his fingers, After grabbing her. he pushed her backwards, She fell
backwards onto his car, She hit the bumper of his car with her thigh, The impact of her being
pushed into the car left a large bruise on her left thigh, Throughout the physical confrontation.
the Defendant was yelling profanities at the Plaintiff such as "You're a bitch, You're a whore,
He took you from me, You are selling yourself, The Plaintiff did not call the police, but
photographs of the injuries were taken by the Family Law Clinic on March 2, 1995.
WHEREFORE, plaintiff prays that the petition be filed and service shall be made
without payment of costs per 23 Pa,C,S. ~6106(b),
Respectfully submitted,
Date J ~Yt' j 9fj
;k.11~ f-
THOM S M, PLACE
LINDA E, FISHER
ROBERT E, RAINS
Supervising Attorney
THOMAS L, PEELER
Staff Attorney
FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
717/243-2968
SHERI FF I S RE'IURN
CCM1C'M'IEAL'Ill OF PENNSYLVANIA:
COONTY OF CLMBERLAND
In The Court of Cammon Pleas of
Cumberland County, Pennsylvania
No. 95-1199 Civil Term
Temporary Protective Order Notice and
Petition for Temporary Protective
Order
Febecca J. Mi tchell
vs
CHarles W. Mitchell
Kenneth Gessert
, ~ Deputy Sheriff of
Cumberland County, Pennsylvania, wno being duly sworn according to law, says,
that he served the within Temporary Protective Order Notice and Petition for Tempprary
Protective Order
Upon Charles W. Mitchell , The defendant at 12:05 o'clock
p.M. EST / ~. on the
day of
08
March
, 19~ at
430 Pine Dale Road. Carlisle
Pennsylvania. by handing to
.Cumberland County,
Charles W. Mitchell
a true and attested copy of the Temporarv Protective Order Notice and PEtition for,
Temporary Protective Order
and at the sane time directing his attention to the contents thereof and
the "Notice to Plead" endorsed thereon.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
18,00
4,48
22.48
.
So answers: , /
--,,-/'; .?/ //4
7- /~;"7:t"'1'=(":Io.",-'~~'l-:::::;"'d
I I
R. Thanas Kline. Sheriff
Sworn and subscribed to before me
this 16-!- day of 71/4..<.1...,1
by/qr.~
Deputy Sheriff
19 ~h/ A.D.
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I' ..,
Prothonotary
REBECCA J, MITCHELL.
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION . LAW
: PROTECTION FROM ABUSE
v,
CHARLES W. MITCHELL,
Defendant
: NO, 95. 1199 CIVIL TERM
PRAECIPE TO WITHDRAW PETITION
Please withdraw the above captioned Petition for Protection From Abuse which was filed
on March 6, 1995.
To:
Prothonatary
Date: ;(r, r /.5., ly1..6
(~
:J./wHI Il, J;L.
Robe , Rains
Thomas M, Place
Linda E, Fisher
SUPERVISING ATTORNEY
THE FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
(717) 243-2968
Fax: 243-3639