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Home My WebLink About95-01601 IIAROLD S. IRWIN, III, ESQUIRE AnORNEY ID NO, 299211 36 SOUTII PIn STREET CARLISLE PA 171113 (717) 243-61190 AnORNEY FOR PETITIONER SUZANNE K. WOODALL. Pelitioner vs, ROBERT WOODALL. JR.. Respondent : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY. PENNSYLVANIA : CIVIL ACTION - LAW NO, 95 - i' 0 ( CIVIL TERM PETITION FOR PROTECTIVE ORDER ORDER OF COURT - AND NOW, this l.$tlday of ~ 1995, upon petition of Suzanne K. Woodall, and upon motion of Harold S, Irwin, III, Esquire. it appearing that the parties have reconciled, the Protective Order and Order for Exclusive Possession entered on April 7, 1995 in this matter is hereby vacated. BY THE COURT, <- = .... ,....., co -, N > .... -= ;',"' ~ ":',r1 :3: ,. ,.-. ..( ;'~ - u:> c.n 4. Since that date. the parties have reconciled and resumed cohabitation, 5. Petitioner believes and therefor avers that there is no longer any need for a protective order or order for exclusive possession of the marital home. WHEREFORE, petitioner requests this Court vacate its order of April 7, 1995. ~y 36 South Pitt Street Carlisle, PA 17013 (717) 243-6090 Supreme Court I.D, NO. 29920 ~ I, Suzanne K, Woodall, petitioner herein. verilY that the facts contained herein are true and correct. 1 understand that false statements herein are made subject to the penalties of 18 Pa.C.S, Section 4904 relating to unsworn falsification to authorities, July '20, 1995 , i \:, Qo.~ ............~ - !:? ") ~ ~ ,:;/".. -. 1 ~ . _. . '>J " .' r..., - -- ,-" ~ .J ~.) -.., ~ t) ~ II: .... Ul QJ c:: I>l .0: I>l c:: QJ > I>l.o: l::t 0 'tl H ..:Il1. xII: .... c:: Eo< l1. 11:0 ..... . 0 0 ~ ... .~ w w . IJ. W ~ ..:I.... .... ~ z ><.0: Eo< > ..:I.... II: III Eo< ~~ OEo<..:I H .o:QJ '" QJ 0 Ii ~z ..:I l::tl1. II: II: 01 H t 0 . l1. 00 > 0 ..:I i~~ i8 OOZH~ ~ ..:I WII: ~ ~::: 00 .0: Eo<w ....,: ~~ ~l::tH 0 . l::t .o:l::t ~ti \1' o ~ Eo<... g: . III 0 ....\1 :.: > 011: ~~ 00 0 .0:0 ~ i! ..... .... Eo< ..:I .0: \0 II: W ~ > ~:]~ ;:,r 11:11: ... Z OW..:lI~ Eo< 0 ~~ O~HItl ~ II: Eo< COIl: o ~O\z W a:: t'l III Z ~ 5 woo. ::: 0 0 0 :I: 0 Ul II: H Eo<~ Z Eo< Eo< o H 0 Z Eo< X H I>l l1. ..... . . " . - LAW OFFICES HAROLD S./RW1N. III . ;. /' //." v. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW : PROTECTION FROM ABUSE SUZANNE K. WOODALL, Plaintiff ROBERT WOODALL, JR., Defendant . . 95-1601 CIVIL TERM ORDER OF COURT AND NOW, this 6th day of July, 1995, the Defendant, Robert Woodall,. Jr., now appearing in court on a complaint for indirect criminal contempt with the Public Defender, Ellen K. Barry, Esquire, and it being necessary at this time for the Court to schedule the trial in this matter and to set bail, trial is scheduled for Thursday, July 13, 1995, at 9:30 a.m., in Courtroom No.2, Cumberland county courthouse, Carlisle, Pennsylvania, and bail is set in this matter at $2500.00. By the Court, L_ c.: .- J THOMAS A. PLACEY, ESQUIRE Assistant District Attorney 711LLlrA... 7-1(-11- ELLEN K. BARRY, ESQUIRE First Assistant Public Defender U) Honorable Edgar B. Bayley '" c, ~- ::0:: CCP - u:> u-1 wcy SUZANNE K. WOODALL, plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW PROTECTION FROM ABUSE v. ROBERT WOODALL, JR., Defendant : 95-1601 CIVIL TERM ORDER OF COURT AND NOW, this 6th day of July, 1995, the Defendant, Robert Woodall,. Jr" now appearing in court on a complaint for indirect criminal contempt with the Public Defender, Ellen K, Barry, Esquire, and it being necessary at this time for the Court to schedule the trial in this matter and to set bail, trial is scheduled for Thursday, July 13, 1995, at 9:30 a.m., in Courtroom No, 2, Cumberland County Courthouse, Carlisle, Pennsylvania, and bail is set in this matter at $2500.00. By the Court, J THOMAS A. PLACEY, ESQUIRE Assistant District Attorney ELLEN K. BARRY, ESQUIRE First Assistant Public Defender Honorable Edgar B. Bayley CCP wcy .... ~...'" COMMONWEALTH OF PENNSYLVANIA COUNTY OF: CUMBERLAND CRIMINAL COMPLAINT and PROBABLE CAUSE AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA u..g f"~I.No: 09-2-01 OJ Name; 'Ion. PAULA P. CORREAL Add.... EAST WING - COURTHOUSE 1 COURTHOUSE SQUARE CARLISLE, PA '.........' (717) 240-6564 17013-0000 VS. DEFENDANT: r NAME and AUOnEBB ROBERT WOODALl, JR. 221 WALNUT ST. CARLISLE, PA. 17013 L RACE: Black SEX: Male Docket No,: Dale Flied: OTN: Complaint Numbor Complaint Number. If othor Participants Incldont Numbor 95-001494 ORINO.: 0211500 D,O,B.; 02/27/63 S,S.#: 190-56-1671 R.S.A,; A.K.A,; District AlIorney's ollice 0 Approved 0 Disapproved because: (Whon tho affiant II not a polleD officor os doUnod In Rulo 51 (e) and tho offonso(s) chorgod Includo(l) 0 mlsdomoanor or felony whIch doel not Involva 8 claar and present dangar to any parson or to Iho communIty, tho complaint sholl bo submlUed to tho aUorney for the Commonwealth, who Ihallepprovo or disapprovo without unreasonablo doley). I, OFFIl!~lfo.ftlHN J. SANCENITO 01 NdRTH MIDDLETON TOWNSHIP POLICE Ii'EP^~M'/lNT ..Mtt'!~.P!PMmenlor ~t. fWe!MmIled and Political SubdlYttlonl residing at 211 N, MIDDLETON KJ), t;ARLI:;LI; , PA. 17013 do hereby state: (chock opproprlalo box) 1. 01 I accuse the sbove named delendant, who lives at the address set fonh above or, o I accuse an Individual whose name Is unknown to me but who is described as ($gnatur.. o His nickname or popular deslgnallon Is unknown to me and, therefore, I have designated him herein as John Doe; with violallng lhe penal laws of the Commonwealth of Pennsylvania at 331 CORNMAN RD. (Aae.PoIIIk:aJ S4.lbdMelon) IN NORTH MIDDLETON TOWNSHIP in CUMBERLAND County on or about 07.,.060l95at 0850 Hrs. Participants were: (illhoro woro participants, ploco tholr nomes horo, repoatlng tho nomo 01 abovo dofondent) ROBERT WOODALL JR. 2, The acts committed by the accused were: (Sot forth a summary of tho facll sufflclont to advise tho defende"1 of tho naturo of tho offense charged. Neither tho evldenco nor the Itetute ellogodly vlolatod nead bo cltod, nor shalla citation of tho statuto ellogadly vlolatod, by Itsolf, be suHlclont. In 8 lummary calo, lOt forth a citation of tho .paclflc soctlon and sub-soctlon of the statuto or ordlnanco allegodly violotod). INDIRECT CRIMINAL CONTEMPT - PROTECTION FROM ABUSE ACT SECTION 10190: THE DEFENDANT DID VIOLATE THE ORDER ISSUED UNDER THE PROTECTION FROM ABUSE ACT IN NO. 95-1601 CIVIL TERM ISSUED ON 7th OF APRIL 1995, BY THE HONORABLE JUDGE J. WESTLY OLER, WHICH ORDER DIRECTED THE DEFENDANT NOT TO PUT SUZANNE WOODALl. IN FEAR OF ABUSE IN THAT THE DID BREAK INTO HER RESIDENCE AND FORCE OPEN A DOOR TO A ROOM THAT SHE WAS IN. HE THEN STRUGGLED WITH HER OVER A WOODEN CLUn AND SLAPPED I1ER IN THE FACE. " /30 .Ji,u~ , 1.3 -, -1 AOPC 4126.91 portln.nllnlorm.Uo~.(COnllnu.llon 012.1 \ \ CRIMINAL COMPLAINT and PROBABLE CAUSE AFFIDAVIT Defendant Name: ROBERT WOODALl. JR. Docket Number: all of which were against the peace and dignity of the Commonwealth of Pennsylvania and contrary to the Act of Assembly, or In violation of and of the ""- -- 3, I ask that a warrant of arrest or a summons be Issued and that the accused be required to answer the charges I have made, 4, I verify that the racts set fonh in this complaint are true and correct to the best of my knowledge or Information and belief. This verification is made subject to the penallies or Sect' n 904 f the rimes Code (18 PA. C,S. S4904) relating to unsworn falsification to authorities, .19_ : 'f , ~NlIure or ComplaInant) AND NOW, on this date ;' 19 _, I cenify the complaint has been properly completed and verified, and that there is probable cause for the issuance of process, SEAL lUag....,..,1 o.w.ca 2.3 llUUlrtgAuthoflty1 CRIMINAL COMPLAINT and PROBABLE CAUSE AFFIDAVIT Defendant NaDle: ROBm!' Io.\:lODML JR, Docket Number: ON 07-06-95 AT 0850 Ims, SUZANNE Io.\:lODML CALLED CUlBEmAND CXXJtllY CXM1UNICATIONS AND REPORl'ED 'I1IAT am HUSBIIND, ROBm!' 1o.\:lODML, WAS BREI\KING INlO HER HeME AT 331 CX>RNHAN RD. SUZANNE Io.\:lODML 'roID '!lIE DISPATOIm THAT am HUSBIIND WAS IN 'I11E HeME AND SHE HAD A P.F.A. ORDm JlGAINsr lID! BEING 'lltmE. WlULE ON '!lIE PHONE wrrn 'I11E 911 DISPA'rotm, '!lIE PHONE WEN!' DEAD. SUZANNE Rl1lTm 'I11EN REPORl'ED 'I1IAT roBm!' Io.\:lODML HAD LEFT '!lIE RESIDENCE ON FOOl'. CHIEF RUOOLPII SlOPPED AND DE1rAINED ROBm!' Io.\:lODML A SHORT DIsr/INCE FRCM '!lIE HOUSE, I RESPONDED 'ro 331 CDRNl-Wl RD. AND FOUND /IN AIR CDNDITIONER AND BROKFN ITEMS ON '!lIE FLOJR OF '!lIE HOUSE. 'I11E OOOR 'ro 'I11E BEDOOCl1 WAS DJlMAGED AS WELL, I sroKE WI'I11 SUZANNE Io.\:lODML WlIO ADVISED THAT SHE HAS A P.F,A. J\GAINsr HER HUSBIIND. SlIE SHOOED ME A CDPY OF '!lIE P.F.A. ORDm WlUCH srATFS THAT HE HAS NO PRIVILEnE 'ro BE AT 331 CDRMIIN RD. SUZANNE Io.\:lODML srATED THAT am HUSBAND WAS LIVING wrrn HER UNTIL 'lW:) DAYS NJ.O, AT WHICH TIME SHE FORCED HIM 'ro mvE our. SHE WAS IN BED ON 'l1US DATE WIlEN SHE IIFARD A lDUD mASH AND CALLED 911. ROBm!' Io.\:lODML '!HEN BEXiAN BANGING AT HER OOOR AND YELLING, "YOU BEITER IE!' ME IN!". HE '!HEN F~ OPEN '!lIE BFDOOCl1 OOOR. SHE PICKED UP A mooEN CllJB 'ro DEFEND IIER SELF, HE '!HEN GRABBED IT AND TRIED 'ro TAKE IT FRCM HER. DURRING 'I11E Sffiln>LE HE SlAPPED HER IN '!lIE FACE SEVERAL TIMES. HE '!HEN RlIN our OF '!lIE HOUSE ON ,FOOl'. ~\f\\ {' \j\\:." \.K , 'l \\ ';;" P\'lu'\' '. L\\'I.O ,; ,.- y\~ ~~ ~~, \ \~\J'- . .'. l'~ , ~ ~ I, OFFICER JOlIN J, SANCENITO , DEING DULY SWORN ACCORDING TO LAW, DEPOSE AND SAY THAT TIlE FACTS SET FORTH IN TIlE FOREGOING AFFIDAVIT ARE TRUE AND CO!UtE(:T TO TIlE BEST OF MY KNOWLEDGE, INFORMATION AND BELIEF. di t:. ~'&#"~ f ! Ignature 0 18n Sworn to l1Ie and subscribed hefore l1Ie lhis {. c:L. day of (1~. J ,19n . /D ,) . ;l /./ qi/ no<. /~d'<< . ~'." ,)1 , Dislrict Justice My cOl1lmissiou expires firsl Monday of January, -19- , .:?-ot1, t,) SEAL , AOPC 412C.93 (reproduction) 3.3 ~.-.. , .' l....,.\!.-.., . .,. ,,,. ,,' , . " : I~ ~ ,,:"~ij . . , /Iv..: 1i]J :5{J7?vI:ce-S . I '-"-. - -.....""'- ..- ~ " lCf9t( ~ }~.5U c8s-y u7'Q~J... F='"'Ft!/!c IV ~ 5UZZIJ-NNl:T IJCovlJt[ '3.3/ CotJJ;.1)fN /2..0 \ ~'1lj 3 - ?/ Cj'.;:z (:>0/3 /b(-II-6C) e/p s: ROBeJR... T Woo:]) ItC.L v!.c1'/ I1.)/lLNur 5T: c ll-R..t::r.S! ~ / /l . ;?t/?-36S9 i::06 o?-c:2 7-(;5 3 ,J, !!' II! :;1 II: l!; !:: :1' I, i j~ . 'J !'I :il :ll .1 ;i, : ~ .1: .. .., oj; ~l i \1; " ii' III . 'H oil ',! iI' I , ',I 'II Iii r! .11 I, 'Ii I, q !! I. / HAROLl) S, IRWIN, UJ, ESQUIRE ATIORNEY ID NO, 29920 36 SOUTH PITI STREET CARLISLE PA 17013 (717) 243-6090 ATIORNEY FOR PLAINTIFF SUZANNE K. WOODALL, Petitioner : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA V5. CIVIL ACfION - LAW ROBERT WOODALL, JR., Respondent NO. 9S - 1601 CIVIL TERM PETITION FOR PROTECfIVE ORDER ORDER OF COURT - NOW, this 'lIt day of April, 1995, upon execution of the attached stipulation of the parties, and upon motion of Harold S, Irwin, III, Esquire, the respondent is directed to refrain from abusing, threatening with violence, harassing or visiting petitioner at her residence, her place of employment or in a public place, The respondent is ordered to refrain from having any direct or indirect contact with petitioner including, but not limited to telephone and written communication. The respondent is enjoined from harassing and stalking the petitioner and from harassing the petitioner's relatives. Petitioner is now residing at 331 Cornman Road, Carlisle, PA 17013, the marital home. Petitioner, upon the attached stipulation of the parties, is granted exclusive possession of said marital home and the contents thereof and respondent is prohibited from visiting or being in the area of that residence or any future residen~e as well as petitioner's place of employment or at any other time or place, This order shall remain in effect for a period of one year from the date hereof. I Copies of this order shall be provided to the Pennsylvania State Police and the Carlisle Police Department. Any police officer having reason to believe that the respondent has violated or is violating this order is authorized to arrest respondent without a warrant. If the arrest occurs during business hours of this Court, the respondent shall be produced before this Court at the first available opportunity, If the arrest occurs ~therwise, he shall be taken to a District Justice for the purpose of arraignment and having bail set. A hearing shall then be scheduled in accordance with Cumberland County practice, If the respondent fails to post bail, he shall be produced before this Court at the first available opportunity. BY THE COURT, /, j II (/ f/ {(~L /~ r:)~ ( (-~.) SUZANNE K, WOODALL, Petitioner : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : CIVIL ACTION - LAW ROBERT WOODALL, JR., Respondent : NO. 9S - 1601 CIVIL TERM : PETITION FOR PROTECTIVE ORDER STIPULATION OF THE PARTIES NOW come the parties, Suzanne K. Woodall, petitioner, and Robert Woodall, Jr., respondent, and enter into this stipulation for a protective order under the Protection from Abuse Act, P,L, 1090, No, 218, of 1976, representing as follows: 1. Petitioner is Suzanne K. Woodall, an adult individual residing at 331 Cornman Road, Carlisle, Cumberland County, Pennsylvania 17013, 2. Respondent is Robert Woodall, Jr., an adult individual residing at 221 Walnut Street, Carlisle, Cumberland County, Pennsylvania 17013, 3, The parties were married February 25, 1994, in Carlisle, Cumberland County, Pennsylvania, 4. There have been no children born to this marriage, 5, The marital home, located at 331 Cornman Road, Carlisle, Cumberland County, Pennsylvania 17013, is a rented home. The residence has been rented by petitioner from her grandmother for approximately nine years, respondent is not a party to that oral lease and all furniture and household possessions within the house are the property of petitioner. 6. Respondent neither admits nor denies the averments of abuse or threats of abuse described in petitioner's petition in this action, 7. Respondent, nevertheless. agrees to the entry of a consent order in this case, without the necessity for a hearing or other appearance in court by either party, the contents of which order shall be as follows: A. That the respondent is directed to refrain from abusing, threatening with violence, harassing or visiting petitioner at her residence, her place of employment or in a public place; B. That the respondent is ordered to refrain from having any direct or indirect contact with petitioner including. but not limited to telephone and written communication. C. That the respondent is enjoined from harassing and stalking the petitioner and from harassing the petitioner's relatives, D. That petitioner shall be granted exclusive possession of said marital home , I and the contents thereof and respondent is prohibited from visiting or being in the area of that " residence or any future residence as well as petitioner's place of employment or at any other time or place. E. That this order shall remain in effect for a period of at one year or as otherwise provided by appropriate statutes of this Commonwealth; F. That copies ofthis order shall be provided to the Pennsylvania State Police and the Carlisle Police Department. Any police officer having reason to believe that the respondent has violated or is violating this order is authorized to arrest respondent without a warrant. If the arrest occurs during business hours of this Court, the respondent shall be produced before this Court at the first available opportunity, If the arrest occurs otherwise, he shall be taken to a District Justice for the purpose of arraignment and having bail set. A hearing shall then be scheduled in accordance with Cumberland County practice. Ifthe respondent fails to post bail, he shall be produced before this Court at the first available opportunity. WHEREFORE, the parties request that this Court enter an order providing as aforesaid and for such other relief as the Court deems necessary. uwu1-- I , ! :1, ." .. / . ;oi~*~~:~?&~/ y/1~ ;;(}~LJ.J,-- --r cJ.:?cJ'4.-fl..1 , , / / SUZ' COMMONWEALTH OF PENNSYLVANIA :88: COUNTY OF CUMBERLAND PERSONALLY APPEARED BEFORE ME, a notary public for Cumberland County, Pennsylvania, this 77l' day of April, 1995, Robert Woodall, Jr, And Suzanne K. Woodall, known to me (or satisfactorily proven) to be the persons whose names are subscribed to the within agreement, and acknowledged that they executed the same for the purposes therein contained. IN WITNESS WHEREOF, I have hereu,'!!:_r: my hand and official seal. t\MV2/~ Notary Public Notarial Seal Harold S, Irwtn III. Notary PublIc Ca~I.le Iloro. Cumbe~anCl County My Commission E.plres Sept, 14, 1998 Mentler, f'1lm;yIvlr1aAs9oclallon 01 Nolllnes . ~Q.. I:). , --;:::-"1 ~ ~ en . ILl 0<0< Q ILIZ P: ...:IZ XC p.lLI3:P: ... ... P. 0< lollol 0) C Z ...:IE-<> C 0) o . H 0 'tl r,.. ~ >< I ..:E< or< .c P: r,.. HCJ .... . 0 0 OZZ>Iil ...:lor< e>:a. 0 U 0 0 t-E-< ...:I'" 1":I1II U OHUO 0<0) 0) t<.Ur,.. P: Qp. .e>: ~I 0 U ..0. 0 ...:I QO<O 0 ...:I r,..Z lex>: 3: 0< e>: e>: 0< ...:I .-.0 Q ILl O...:lH It<. . 0 Q 0e>:>1tl l<: 0 e>: UILIHcnz 3: 0 I'lU 0() ILl ~~ 0-< Z r,.. ZE< Z e>: r,..U H 0< ILl r,.. to:! . I'l Zt<. W 0 1II 0 HO P. en > e>: '1 ~ r= ~ ... ::::: ~ ~~ ~i I~t ~~ i; ~Ql!i ~~ 0:. . :5~~ 1Il~ ~~ Cl:: l!l~ ~ S . LAW OFFICES HAROLD S. IRWIN, III SUZANNE K. WOODALL, Plaintiff . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 95-ILP01 CIVIL TERM . . . . v. . . . . . . ROBERT WOODALL, JR., Defendant PROTECTION FROM ABUSE TEMPORARY PROTECTIVE ORDER AND NOW, this 2~(1..day of March, 1995, upon presentation and consideration of the within Petition, and upon finding that the plaintiff, SUZANNE K. WOODALL, now residing at 501 Wagner Drive, Carlisle, Cumberland County, Pennsylvania, is in immediate and present danger of abuse from the defendant, ROBERT WOODALL, JR., the following Temporary Order is entered. The defendant, ROBERT WOODALL, JR., whose current address is 331 Cornman Road, Carlisle, Cumberland County, Pennsylvania, is hereby enjoined from physically abusing the plaintiff, SUZANNE K. WOODALL, or placing her in fear of abuse. The defendant is ordered to stay away from the plaintiff's residence located at 501 Wagner Drive, Carlisle, Cumberland County, Pennsylvania, a residence which is owned by the plaintiff's parents. The defendant is ordered to refrain from having any direct or indirect contact with the plaintiff inCluding, but not limited to, telephone and written communications. The defendant is enjoined from harassing and stalking the plaintiff and from harassing the plaintiff's relatives. The defendant is enjoined from entering the plaintiff's place of employment. A violation of this Order may subject the defendant to: (i) arrest under 23 Pa. C.S. S6ll3; (ii) a private criminal complaint under 23 Pa. C.S. 56311.1; (iii) a charge of indirect criminal contempt under 23 Pa. C.S. 56114, punishable by imprisonment up to six months and a fine of $100.00 to $1,000.00; and (iv) civil contempt under 23 Pa. C.S. S6ll4.l. Resumption of co-residence on the part of the plaintiff and defendant shall not nullify the provisions 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 ~isk of harm to the plaintiff. This Order shall remain in effect until modified or terminated by the court after notice of hearing. A hearing shall be held on .., {)./M. ' , the r ~ day of -7- ~ .v , , o'clock, ~ .m. in Courtroom No.5, Cumberland this matter on ::j/<, :.La:! 1995, at.3~ 3D County Courthouse, Carlisle, Pennsylvania. This Order shall be docketed in the office of the Prothonotary and forwarded to the Sheriff for service upon payment of the Sheriff's fee. The Prothonotary shall not send a copy of this Order to the Defendant by mail. The Pennsylvania State Police and the Carlisle Police Department will be provided with certified copies of this Order by the plaintiff's attorney. This Order shall be enforced by any law enforcement agency where a violation occurs by arrest for indirect criminal contempt and without warrant upon probable cause that this Order has been violated, whether or not the violation is committed \.'.. ", ~ '! ~ ',,' . S6, li'.' 115 g 62 s.;: SUZANNE K. WOODALL, Plaintiff . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 95-,UO( CIVIL TERM v. . . ROBERT WOODALL, JR., Defendant . . . . PROTECTION FROM ABUSE 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 does 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 Plaintiff's counsel for his 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 Fourth Floor Cumberland County Courthouse Carlisle, Pa 17013 (717) 240-6200 . . SUZANNE K. WOODALL. Petitioner : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA VS. : CIVILACTION-LAW : NO,9S.J~OI CIVILTERM . : PETITION FOR PROTECTIVE ORDER ROBERT WOODALL, JR., Respondent PETITION FOR PROTECTIVE ORDER and for EXCLUSIVE POSSESSION -- NOW comes petitioner, Suzanne K. Woodall, by her attorney, Harold S. Irwin, m, Esquire, and presents this petition for a protective order under the Protection from Abuse Act, P.L. 1090, No. 218, of1976, representing as follows: 1. Petitioner is Suzanne K. Woodall, an adult individual residing at 501 Wagner Drive, Carlisle, Cumberland County, PeMSylvania 17013. 2. Respondent is Robert Woodall, Jr" an adult individual residing at 33 I Cornman Road, Carlisle, Cumberland County, Pennsylvania 17013, 3. The parties were married February 25, 1994, in Carlisle, Cumberland County, PeMSylvania, while respondent was an inmate in Cumberland County Prison. 4. There have been no children born to this marriage. 5. The parties' residence at 331 Cornman Road, Carlisle, Cumberland County, Pennsylvania 17013, is a rented home. For her own safety, petitioner has vacated the premises and is living with her parents due to respondent's refusal to vacate the marital home. However, the residence has been rented by petitioner from her grandmother for approximately nine years, respondent is not a party to that oral lease and all furniture and household possessions within the house are the property of petitioner. 6. Since respondent's release from prison in December, 1994, petitioner has been , subjected to a variety of verbal and physical abuse from respondent causing her to leave the marital home for her own safety. Such verbal and physical abuse has consisted, inter alia, in the following: A. Approximately three to four times each week since the parties have been together over that period, respondent has verbally threatened to kill petitio,ner; B. On several occasions throughout that period, respondent has physically grabbed petitioner around the neck and choked her violently until she has agreed to his various demands at those times; C. On at least two occasions, on March 10, 1995 and earlier in FeblUlUy, 1995, respondent has physically hit petitioner with a billy club causing serious pain and discomfort; and pt-"" .=-, S', = a- n ~c =<> ';t> ~ " ,...., ..,>;' '" " ~ . -. <D -t. c5 .' 'l) - ~~ co r;', ~ (;-, (,l ~ lJ - l' -; VI '\ -J Q J'l c> If) . -- ,-" 0 V, el 0 '""'" iJ'i '. = r.: ~' 1>- .... ~!" Ui !v') 11 -< II- U'O .... 0 p 1 1-