HomeMy WebLinkAbout95-01321
.
,
~k,
~~,'
?n~:...'
~,/?J
'0
-
"",:~~~%
"---";-t~~.
,.:,i,_.",~_
,:/1
, . -"':\$
:';:~~fE~
""Ii!
r~j
.~
-'~~
<"\:~
" ;-:,~\~*
" ):1"
-':<'.~1j1
\~~
';~it~:
,.~, :;{1.'
,).."f
:n1
<~~-
as
('0
",.-
I
lO
a-
_.';.1-
: ~'..~J;,
, .
-<>-~
'.,":
',.--,.-
"".)'
-:i:11~
-\t~
.,.,"
,it.
: ~,~
o
Z
'.
..
.....
\
~
,- .-.
. .~.-
The defendant Is enjoined from harnssing and stalking the
plnintiff and from harassins the plaintiff's relatives, or her
minor' child.
The defendant Is enjoined from entering the plaintiff's
place of employment or the school of the minor child.
The defendant is enjoined from removing, dalllasing,
destroyins or selllns any property owned Jointly by the parties
or owned solelY by the plaintiff.
A violation of thiR Order may Rubject the defendant to: i)
urrest undor 23 Pa. C.S. g6113; ii) a private criminal complaint
under 23 Pa. C.S. g6113.1; ili) a charge of indirect criminal
contompt under 23 Pa. C.S. g6114. puniRhable by imprisonment up
to six monthH and a fino of $100.00-$1,000.00; and iv) civil
contempt under 23 Pa. C.S. g61i4.1. ReHumptlon of co-reHidence
on tho purt of the plaintiff and defendant Hhall not nullify the
provIsionH of the courl, order.
This Or'der shall r'omuln In effoct IlnLl! mOllified or
terminated by the COlll't after' notice or headns. A hear'ing shull
be held on thiH matter on the
,) { 'I' " 3d
,?,-11.:, day of ~ltlJ'ch, 1995, at
~,m"
,
(/
in COIlI'Lr'oom No,_, Cllmbel'land COllnty Cour'thollse,
Carlisle, Pennsylvania.
'fhe plaintiff ma)' proened withollt pl'e-payment of fees
pending a fllrther ord('r a!'lol' Lhe h"al'ing,
'I'he CIlIIII"."I'land COllnty Sh..l'i "f's OepuI'tm..nt Hhall uLtompt to
multe >lervlce at tho plalnt.lff's 1''''IIlI'HI. and Idl.holll. I'po-payment.
This Order shul I be docketed in Lhe office 01' Lhe
01' fees, bill. sel'vlce I1IIIY bo uccol1lpl i81ll'd lindoI' uny uPl'1Icllblo
rille of Civil Procodul'o.
Prothonotary und forwnrded to the Sheriff for sorvlce. The
Prothonotnry shull not send II copy of this Order to Lhe defondunt
by mall.
The Eust Ponnsbol'o police Depnrtment, will be provided with a
certified copy of this Order by the pluintiff's nttorney. This
Order shall be enforced by any law enforcement ngency where u
violation occurs by arrest for indirect crlminul 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 be tnken without unnecessary delay
before the court that issued the order, When that court is
unavailable, the de fendant. shal I ~,~ Lakey be fore the nppropriate
diBtdct justice. (23 P.S. .~ 6113)/./ ,
"( :"0 Itt 0
~~~ ~
-w-.Jlldge r /~\ // /.jc.n
r'
,
Rohin .1, nl\ll',
TN TilE COUH1' 011 CO~IHONPIJEAS OF
CUMnERLAND COUNTY. PENNSYLVANIA
"
Pll\intlff
and on behalf of hor
minor child:
Dl\vid 1', 1.\ t.Lle, ,Jr'.
NO. 95-
CIVIl. 'I'F.ml
VS,
Richard M. Dobson,
Defendnnt
PRO'l'F.C1'JON FROM AOUSE
NOTICE
,
You have been sued in court. If you wish to defend against
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
fail to do so 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,
FEES AND COSTS
If the case goes to hearing and the judge grants a
Protection Order, a surcharge of $25,00 will be assessed against
you. You may also be required to pay attorney fees to Legal
Services, Inc. for their representation of the plaintiff.
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
office 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
Robin J, Bair,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
and on behalf of her
minor child:
David T. Little, Jr.
NO. 95-
CIVIL TERM
PROTECTION FROM ABUSE
vs.
Richard M, Dobson,
"Defendant
PETITION FOR PROTECTION ORDgfi
RELIEF UNDER THE PROTECTION FROM ABUSE
ACT, 23 P.S. 6 6101 et seq.
A. ABU~
1, The plaintiff, Robin J. Bair, is an adult individual
residing at 8 N. Enola Drive, Enola, Cumberland county,
Pennsylvania 17025.
2, The defendant,Richard M. Dobson, is an adult individual
residing at 530 W. Cumberland Road, Enola, Cumberland County,
PennsYlvania, 17025.
4. The defendant has had an intimate relationship with the
plaintiff,
5. Since approximately November 1994, the defendant has
attempted to cause and has intentionally, knowingly, or
recklessly caused bodily injury to the plaintiff, has placed the
plaintiff and her minor child in reasonable fear of imminent
serious bodily injury, and has knowingly engaged in a course of
conduct or repeatedly committed acts toward the plaintiff
including following the plaintiff, without proper authorization,
under circumstances which placed the plaintiff in reasonable fear
of bodily injury. This has included, but ;s not limited to, the
following specific instances of abuse:
a. On or about February 24, 1995, the defendant repeatedly
called the plaintiff. The last time the defendant called
the plaintiff she hung up on himj he then came to her
residence, kicked in the front door of her apartment
breaking the lock, grabbed the plaintiff by her throat, and
pushed her against a wall. The defendant threatened that he
was going to harm her if she didn't drop the criminal
charges against him, When the plaintiff told the defendant
that the pOlice were coming, he left her apartment. Minutes
later, the defendant returned, grabbed the plaintiff by the
throat with both his hands and pushed her down the hall.
When the plaintiff was able to break free from the
defendant's grip, she ran into the bathroom, The defendant
knocked pictures off of the wall, went into the bathroom,
and slapped and punched her in the face and on the back of
her head causing swelling on her head. When the police
arrived and she told them she wanted to press charges
against the defendant, he lunged at her and threatened her
saying, "I'll get you, bitch'" The police handcuffed the
defendant and took him into custody,
b. On or about February 15, 1995, the defendant repeatedly
called the plaintiff and then came to her residence early in
the mornin9 repeatedly yelling at the plaintiff, pounding on
2
her door, and threatening to kick the door in if she didn't
open it. When the plaintiff oponed the door, the defendant
grabbed her by the throat and pushed her into the bedroom.
With his free hand he grabbed the phone, dialed the East
Pennsboro POlice, and told her to tell them she wanted to
drop the criminal charges against him, When the phone line
was busy, the defendant called the plaintiff names and hit
her with the phone receiver on her forehead causing swelling
and bruising. When the plaintiff covered her face with her
hands, tha defendant repeatedly punched her causing bruises
on both her hands. Duri~g this incident, a babysitter
phoned the police, When she saw that the pOlice had arrived,
the babysitter attempted to run outside, but the defendant
grabbed her, The police ordered him to let her go and then
escorted the defendant out of the premises and charged him
with trespassing,
c. On or about January 20, 1995, when the plaintiff awoke,
she was startled and fearful to see the defendant standing
near her. The defendant ripped the plaintiff's telephone
cords from the wall, made her sit on the couch while he went
through her personal belongings, and then he repeatedly
punched her in the face causing her to have a bruised eye
and swollen nose, The defendant continued to rant and
repeatedly punched the plaintiff about the face and body
until she told him that because of her bad heart she needed
3
to go to the hospital. The defendant put the plaintiff in
his car and took her to the Harrisburg Hospital where she
called the police and then was treat~d for her injuries.
d. On or about January 15, 1995, when the plaintiff
returned home and found the defendant sitting in her house,
she feared for her safety and left the residence. The
defendant ran after her and grabbed har by the hair, The
plaintiff broke free and ran to her car, but before she
could get the door completely closed, the defendant
forcefully pulled the door open and repeatedly kicked the
inside of the car door breaking it so that it did not close
completely, The defendant grabbed the plaintiff by the
throat causing her pain. When the defendant let go of the ..
plaintiff, she drove away in the car.
,
e. On or about December 25, 1994, the plaintiff's son ran
into the plaintiff's bedroom to get away from the defendant
who was running after him. The plaintiff grabbed the child,
put him on the bed and stood between him and the defendant.
When the defendant forced his way around the plaintiff, he
grabbed the plaintiff's son by the throat causing bruises.
When the plaintiff tried to pull the defendant off of the
child, the defendant grabbed her by the throat and pushed
her against a wall, A neighbor intervened and pUlled the
defendant off of the plaintiff escorting him from the house.
The defendant threatened tQ "trash" the plaintiff's house,
4
as he knocked a mirror and several picture frames off of a
wall.
f, On or about December 24, 1994, the defendant jumped
into the plaintiff's car where her son was sitting and drove
away causing the plaintiff to fear for her son's safety.
The plaintiff called the po1ico, hut before they arrived,
the defendant returned with her car, grabbed the plaintiff,
and punched her in the mouth causing it to bruise, swell and
bleed. With his other hand, the defendant punched the
plaintiff on the side of her head knocking her to the ground
and causing her to lose consciousness. When she regained
consciousness, the defendant and the plaintiff went into the
house where the defendant ripped the phone wires out so that
she could not call anybody, took the plaintiff's car keys,
and left the residence,
g, On or about November 24, 1994, the defendant got out of
his vehicle wielding a steel bar threatening the plaintiff,
When the plaintiff went to her residence, the defendant
followed her, kicked in her door, grabbed the plaintiff,
punched her in the face, ripped her clothing, and threatened
her by telling her to sit quietly or her would kill her.
The defendant made the plaintiff go back to the bedroom
where he broke several items including but not limited to
the following: a telephone, an antique kerosene lamp, 10
picture frames, and a VCR/Color TV, The defendant then
5
pushed the plaintiff onto the bed and tried to force sex on
the plaintiff, When she was able to break free, she ran
outside where someone picked her up and took her to a phone
to call the police.
6. The plaintiff believes and therefore avers that she and
the minor child are in immediate and present danger of abuse from
the defendant and that they are in need of protection from such
abuse.
7. The plaintiff desires that the defendant be prohibited
from having any direct or indirect contact with the plaintiff or
her minor child including, but not limited to, telephone and
written communications,
8. The plaintiff desires that the defendant be enjoined
from harassing and stalking the plaintiff, and from harassing the
plaintiff's relatives, or her minor child,
9. The plaintiff desires that the defendant be restrained
from entering her place of employment or the school of the minor
child,
10. The plaintiff desires that the defendant be enjoined
from removing, damaging, destroying or selling any property owned
jointly by the parties or owned solely by the plaintiff.
B. EXCLUSIVE POSSESSION
13. The apartment from which the plaintiff is asking the
Court to order the defendant to stay away is rented in the name
of the plaintiff.
6
14. The defendant has his own residence located at 530 W.
Cumberland Road, Enola, Pennsylvania.
C. LOSSES and ATTORNEY FEES
15. The plaintiff has suffered losses as a result of the
abuse by the defendant. The losses are listed on Exhibit A
attached.
16. The plaintiff asks that the defendant be ordered to pay
reasonable attorney fees to Legal services, Inc.
WHEREFORE, pursuant to the provisions of the "Protection
from Abuse Act" of October 7, 1976, 23 P.S. 6 6101 et sea., as
amended, the plaintiff' prays this Honorable Court to grant the
following relief:
A. Grant a Temporary Order pursuant to the "Protection from
Abuse Act:"
1. Ordering the defendant to refrain from abusing the
plaintiff or her minor child or placing them in fear of
abuse.
2, Ordering the defendant to refrain from having any
direct or indirect contact with the plaintiff or her
minor child including, but not limited to, telephone
and written communications,
3. Ordering the defendant to refrain from harassing
and stalking the plaintiff and from harassing the
plaintiff's relatives and her minor child,
7
,
,
I
I'
!
!
~
I
I
4, Prohibiting the defendant from entering the
plaintiff's place of employment and the school of the
minor child.
5. Prohibiting the defendant from removing, damaging,
destroying or selling property jointly owned by the
parties or owned solely by the plaintiff;
6. Ordering the defendant to stay away from the
plaintiff's residence located at 8 N. Enola Drive,
Enola, Cumberland County, PennsYlvania.
8, 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 order to be in effect for a period of one year:
1. Ordering the defendant to refrain from abusing the
plaintiff or her minor child or placing her in fear of
abuse.
2, Ordering the defendant to refrain from having any
direct or indirect contact with the plaintiff or her
minor child including, but not limited to, telephone
and written communications.
3, Ordering the defendant to refrain from harassing
and stalking the plaintiff and from harassing tho
plaintiff's relatives and her minor child,
8
4. Prohibiting the defendant from entering the
plaintiff's place of employment or the school of the
minor child.
5. Prohibiting the defendant from removing, damaging,
destroying or selling property jointly owned by the
~arties or owned solely by the plaintiff.
6. Ordering the defendant to stay away from the
plaintiff's residence loceted at 8 N. Enola Drive,
Enola, Cumberland county, Pennsylvania.
7. Ordering the defendant to stay away from any
residence the plaintiff may in the future establish for
herself.
8. Ordering the defendant to reimburse the plaintiff's
out-of-pocket losses suffered as a result of the abuse
including but not limited to the losses listed on the
attached sheet marked Exhibit A.
9. Ordering the defendant to pay reasonable attorney
fees to Legal Services, Inc.
The plaintiff further asks that this Petition be filed and
served without payment of fees and costs by the plaintiff,
pending a further order at the hearing, and that a certified copy
of this Petition and order be delivered to the East pennsboro
Township Police Department who has jurisdiction to enforce this
9
The above-named plaintiff, Robin J, Bair, verifies that the
statements made in the above Petition are true and correct.
Plaintiff understands that false statements herein are made
i'
sUbject to the penalties of 18 Pa, C.S, 04904. relating to
unsworn falsification to authorities.
Date: :32-- IS .,Cj ')
~~ iJ1
laintiff
, A.' '" . ",
Robin J. Bair,
Plaintiff
and on behalf of her
minor child:
David T. Little, Jr.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 95-
CIVIL TERM
vs,
Richard M. Dobson,
Defendant
PROTECTION FROM ABUSE
OUT-OF-POCKET LOSSES
The plaintiff requests that the defendant reimburse her out-
of-pocket losses, including but not limited to the following:
VCR/color TV
ATT Telephone with built-in intercom system
$
400.00
150.00
,
Antique kerosene lamp (estimate not available at this time)
20 pictures frames
Home Interior Mirror
100.00
60.00
Repair of Car door (estimate not available at this time)
Repair lock on door
28.00
Exhibit A
:f:4
Gl
~I~
Q
C'
y::,::,
r' ,
~.
n
o
\'):=-:
,_ I,
1':1;. 'f
:':~. :t~,:' ~ .' i'-:'
, '
-..(...1
....11
"'<"'::.:'
..
,.
.,.
~
:.,
-
..c:..
'-
'"
.t::'
."
'-'"
.::::::
-
~
lJHIilJU FF' lJ I\&:TUAN
CASIil NOI 11111&-01321 P
COMMONWEALTH OF PIilNNlJ~VAN%AI
COUNTY OF CUMBIilRLAND
aA'%R. AOaXN :r
VlJ.
DOBSON AXCKARD M
T%MO'1'HY _%'1'2
, Bher~~~ or Doputy lJher~~~ o~
CUMBIilRLAND county. ponnDy~van~a. who bo~ng dU~y Dworn accord~ng
to ~aw. Day.. that he Dorvod tho w~th~n
upon DOBlJON ~CKARD M
P~'1'IilC'1'%ONFAOH ABUlJlil
tho
d.randant, at
8 I S5 HOUI\B, on tho 1.6th day o~ March
.
111U at
CUMBIlRLAND COUNTY PJUlJON 1.101 c~%1U240N'1' ~"D
,C'UMB&:RLAND
.
CA~ZSLS. PA 17013
JUcHARD M, DOBlJON
county. ponnDy~vania. by hand~ng to
D&lFIlNDANT
a ~CU. and attQutad copy or th_
P~TIlCT%ON FAOH AaUlJll
.
and at tho .ame t~me d~roct~ng Hi. attant~on to tho contantD tharao~.
Shal:J.t:'r'SI calltll.
Dockot~ng
8orv;Lao
A~~~dav~t
SurchArge
lJo anDwarDI p' ,:/.f'?
~;"J,,, " , .,/:.. /.C :_"
~-f?"'("''''~ 'I ,....-." .
~. Thom~1I K~nQ, snacJ.tr
,
1.8.00
Z.80
.00
.00
620.80
00/00/0000
by
sworn and lIub~aa:1bQd to barOrQ mo
th~. .t.l~...{ day o~ )11'...,t.-/
19 .,., A. O.
~L."v G' 7JI""',:;,,
I I PE'oChonotar
,-
A~U.J ')'
,
i (
, . \ ~~ ,.
Ct;Il'I'II'ICA'rrON OF PI.'A ':>
Case Number fI.f; /32.1 cuM.i. T.r.,l.-t......
Name 'R,j,e)Liud- 171 ' ,-f)t-r(~
.f 30 '1V ut (:.u.,k,'Ii aAt.:L
{;ltAc,- fA 17025'
,
Victim's Name:
1? .c-t.M\.. q. VaM..-
v
Balance Due: $ ~3, 00
ADD
DELETE
$
$
$
$
$ 63.00
170 State Surcharge
171 State Fine
260 Sheriff Cost
$
$
$
502 Restitution
$
Name f<. &I.~
Address 8 IJ,
~' i3tWv
, ''n<...f tL iJ JtA.I-<-<'-
City
f4~'^-'
state..fJ1.. Zip /702.:r
Name
Address
$
City
State _ Zip
Name
Address
$
City
state ____ Zip
Prothonotary Office
Person CertifyJ.ng Infor.ll1atJ.on 110j.I.{~"tI,>-_,~~ Dille 3/U/9,f"
. ,~
..,~...
I
r
Robin J, Bair,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 95-1321 CIVIL TERM
PROTECTION FROM ABUSE
Plaintiff
and on behalf of her
minor child:
David T, Little, Jr,
vs.
Richard M, Dobson,
Defendant
OUT-OF-POCKeT LOSSES
The plaintiff requests that the defendant reimburse her out-of-
pocket losses, including but not limited to the fallowing:
ATT telephone with built-in intercom system (toward repair$ 10.00
Antique kerosene lamp (estimate not available at this time) 0.00
20 pictures frames (toward repair or replacement) 25,00
Repair of car door (estimate not available at this time)
Repair lock on door
28.00
$ .00
Reimbursement of losses through this action does not constitute a
bar to litigation for civil damages for injuries sustained from
acts of abuse giving rise to the award or a finding of contempt
under the Protection From Abuse Act.
Exhibit A
CRUTIFICATION OF PFA'S
CiJ130 Numbor q.f- /321 ('...l,d T...,l.-H'-
Namo 'R.0ltlAeL 711 ' ,j)ol'-U"v
.)30 )1o'Ut. CWII.J!V. v/a 11.:A-
f:lL.H...<.- fA 170)S
Victim's Name:
-R.l..(o.il'- ~. t3.L~
v
Balance Due: $ 0.3.00
ADD
DELETE
$
$
$
$
$ 63.00
170 State Surcharge
171 State Fine
260 Sheriff Cost
$
$
$
502 Restitution
$
N a me R a-I.ci",-,
Address R N.
~' fj,tVv
, .11.<4:'.:t.. ~) M."~
'City
[~~'^--'
State 1il Zip /702S
Name
$
Address
City
State
Zip
Name
Address
$
CI ty
State
Zip
Prothonotary Offico "
Person Certifying Information ~-1,~L'*tk_Gl. J'Y.l~tc:..w.. Diltl) ..f./;'L!:.l{..
Robin J. Bair,
IN THE COURT OF COMMON PLEAS OF
plainti ff
and on behalf of her
minor chi ld:
David T, Little, Jr.
CUMBERLAND COUNTY, PENNSYLVANIA
NO, 95-1321 CIVIL TERM
PROTECTION FROM ABUSE
vs,
Richard M. Dobson,
Defendant
AND NOW, this
E.!WTECTIOlLQRDER
~
I..... day of March, 1995, upon consideration
of the Consent Agreement of the parties, the following Order is
entered:
1. The defendant, Richard M. Dobson, is enjoined from
physically abusing the plaintiff, Robin J, Bair, and her minor
child, David T. Little, Jr., and/or from placing them in fear of
abuse.
2. The defendant is enjoined from having any direct or
indirect contact with the plaintiff or her minor child including,
but not limited to, telephone and written communications.
3. The defendant is ordered to refrain from harassing and
stalking the plaintiff and from harassing the plaintiff's
relatives and the plaintiff's minor child.
4. The defendant is prohibited from entering the
plaintiff's place of employment and the school of the plaintiff's
child except for business relating to the defendant's relatives
who also attend the school,
5. The defendant is prohibited from removing, damaging,
destroying or selling any property owned solely by the plaintiff
or jointly owned by the parties.
6. The defendant is excluded from the plaintiff's residence
located at 8 North Enola Drive, Enola, Cumberland County,
Pennsylvania.
7. The defendant is ordered to stay away from any residence
the plaintiff may in the future establish for herself.
8. The defendant is ordered to reimburse the plaintiff's
out-of-pocket losses suffered as a result of the abuse including
but not limited to the losses listed on the attached sheet marked
Exhibit A, The total amount of losses shall be reimbursed to the
plaintiff within 60 days of the entry of this Order,
Reimbursement of losses through this action shall not constitute
a bar to litigation for civil damages for injuries sustained from
acts of abuse giving rise to the award or a finding of contempt
under the Protection From Abuse Act.
9. The court costs and fees, including filing and service
fees, are waived.
10, This Order shall remain in effect for a period of one
(1) year or 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 an act of abuse or
has engaged in a pattern or practice that indicates risk of harm
to the plaintiff.
11. This Order may subject the defendant to: i) arrest
under 23 Pa. C,S, 66113; ii) a private criminal complaint under
23 Pa. C.S. 66113.1; iii) a charge of indirect criminal contempt
under 23 Pa, C,S, 66114, punishable by imprisonment up to six
months and a fine of $100.00-$1,000.00: and iv) civil contempt
under 23 Pa. C.S, 66114.1. Resumption of co-residence on the
part of the plaintiff and defendant shall not nUllify the
provisions of the court order,
12. The East Pennsboro Township Police Department shall be
provided with a certified copy of this Order by the plaintiff's
attorney and may enforce this Order by arrest for indirect
criminal contempt without warrant upon probable cause that this
Order has been violated, whether or not the violation is
committed in the presence of the police officer. In the event
that an arrest is made under this section, the defendant shall be
taken without unnecessary delay before the court that issued the
order. When that court is unavailable, the defendant shall be
taken before the appropriate district justice. (23 P.S. 6 6113).
By the Court,
.~J
Hess, JUdge
,
A" ' , '
'.
.".' ,
:. \~ .l~ , ': ,;ejl'
.1~: I ,:
ii!
56. nv !Jl 01
i'l \i'll
t(,'''1
. .
i
Robin J. Bair,
IN THE COURT OF COMMON PLEAS OF
Plaintiff
and on behalf of her
minor child:
David T. Little, Jr.
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 95-1321 CIVIL TERM
PROTECTION FROM ABUSE
vs.
Richard M. Dobson,
Defendant
OUT-OF-POCKET LOSSES
The plaintiff requests that the defendant reimburse her out-of-
pocket losses, including but not limited to the following:
ATT telephone with built-in intercom system (toward repair$ 10.00
Antique kerosene lamp (estimate not available at this time) 0.00
20 pictures frames (toward repair or replacement) 25.00
Repair of car door (estimate not available at this time)
Repair lock on door
28.00
$ .00
Reimbursement of losses through this action does not constitute a
bar to litigation for civil damages for injuries sustained from
acts of abuse giving rise to the award or a finding of contempt
under the Protection From Abuse Act.
Exhihit A
A - ....-
, .. . " '". .
-- . . - ...~ . ---- -~._~".--~
Robin J. Bair,
Plaintiff
and on behalf of her
minor child:
David T, Little, Jr,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 95-1321 CIVIL TERM
vs,
Richard M. Dobson,
Defendant
PROTECTION FROM ABUSE
This Agreement is
CONSEtiL..M1REI;!i.EiliI .. _
1 'J ')o..~
entered on this ~ day of
March, 1995,
by the plaintiff, Robin J, Bair, and the defendant, Richard M.
Dobson. 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 agree that the
following may be entered as an Order of Court.
1. The defendant, Richard M, Dobson, agrees to refrain
from abusing the plaintiff, Robin J. Bair, or her minor child,
David T. Little, Jr., and/or placing them in fear of abuse.
2, The defendant agrees not to have any direct or indirect
contact with the plaintiff or her minor child including, but not
limited to, telephone and written communications.
3. The defendant agrees not to harass and stalk the
plaintiff and harass the plaintiff's relatives and the
plaintiff's minor child,
4. The defendant agrees not to enter the plaintiff's place
of employment or the school of her minor child except for
business relating to the defendant's relatives who also attend
the school,
5, The defendant agrees not to remove, damage, destroy, or
sell any property owned solely by the plaintiff or jointly owned
by the parties,
6. The defendant agrees to stay away from the plaintiff's
residence located at B North Enola Drive, Enola, Cumberland
County, Pennsylvania,
7. The defendant agrees to stay away from any residence
the plaintiff may in the future establish for herself,
B. The defendant agrees to reimburse the plaintiff's out-
of-pocket losses suffered as a result of the abuse including but
not limited to the losses listed on the attached sheet marked
Exhibit A, The total amount of losses shall be reimbursed to the
plaintiff within 60 days of the entry of the Protection Order.
Reimbursement of losses does not constitute a bar to litigation
for civil damages for injuries sustained from the acsts of abuse
giving rise to the award or a finding of contempt under the
Protection From Abuse Act.
g, The defendant, although entering into this Agreement,
does not admit the allegations made in the Petition,
10, The defendant understands that the Protection Order
will remain in effect for a period of one (1) year or 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 an act of abuse or has engaged in a
pattern or practice that indicates risk of harm to the plaintiff.
the Protection Order entered in this matter shall be in effect
for a period of one year,
11. The defendant understands that this Order is
enforceable in the same manner as the Court's prior Temporary
Protection Order entered in this case. Violation of the
Protection Order may subject the defendant to: i) arrest under 23
Pa. C,S, 66113; ii) a private criminal complaint under 23,Pa.
C,S. 66113,1; iii) a charge of indirect criminal contempt under
23 Pa. C.S, 66114, punishable by imprisonment up to six months
and a fine of $100.00-$1,000.00; and iv) civil contempt under 23
Pa, C,S, 66114,1, Resumption of co-residence on the part of the
plaintiff and defendant does not nullify the provisions of the
court order.
WHEREFORE, the parties request that a Protection Order be
/' /"-
entered to reflect the above terms". /,/~ .' .<//
p, I () aU/[ - l::4 {~
R'o bCi~n~' D-J,' artal'r' p'l'al'ntl'ff
' Richard M, Dobson, Defendant
.'''-I.......J'- ~<-
o n Carey
Attorney for Pla
LEGAL SERVICES, INC.
a Irvine Row
Carlisle, PA 17013
(717) 243-9400
, ,
Robin J. Bair,
IN THE COURT OF COMMON PLEAS OF
Plaintiff
and on behalf of her
minor child:
David T, Little, Jr,
CUMBERLAND COUNTY, PENNSYLVANIA
NO, 95-1321 CIVIL TERM
vs,
Richard M, Dobson,
Defendant
PROTECTION FROM ABUSE
OUT-OF-PQ~~LOSSES
The plaintiff requests that the defendant reimburse her out-of-
pocket losses, including but not limited to the following:
ATT telephone with built-in intercom system (toward repair$ 10.00
Antique kerosene lamp (estimate not available at this time) 0,00
20 pictures frames (toward repair or replacement) 25.00
Repair of car door (estimate not available at this time)
Repair lock on door
28.00
$ ,00
Reimbursement of losses through this action does not constitute a
bar to litigation for civil damages for injuries sustained from
acts of abuse giving rise to the award or a finding of contempt
under the Protection From Abuse Act,
Exhibit A
r, t.~ .
,.....,
,...,
L:)
1-'
': " I-'
',.'tl, :1;-....
j. , =
" ". LD
U'1