HomeMy WebLinkAbout95-01720
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SHERIFF'S RETURN
CASE NO: 1995-01720 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
SWAN BARBARA A
VS.
TRITT WILLIAM H JR
ROBERT L. FINK. SR.
CUMBERLAND County, Pennsylvania,
to law, says, that he served the
. Sheriff or Deputy Sheriff of
who being duly sworn according
within PROTECTION FROM ABUSE
upon TRITT WILLIAM H JR the
defendant, at 1100:00 HOURS, on the 6th day of April
1995 at 48 HORSE KILLER ROAD
SHIPPENSBURG. PA 17257 . CUMBERLAND
County, Pennsylvania, by handing to WILLIAM TRITT
a true and attested copy of the PROTECTION FROM ABUSE
and at the same time directing ~ attention to the contents thereof.
Sheriff's CoStSI
Docketing
Service
Affidavit
Surcharge
18.00
11.76
.00
.00
$2'3.76
So answers I ~ ~
R. ThomC~:-x~::~~
00/00/0000
by
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epu Y erJ.
Sworn and subscribed to before me
7C
this /~ day of qo~
19 q{' A. D.
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,
BARBARA A. SWAN,
IN THE COURT OF COMMON PLEAS OF
Plnint iff
v.
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 95- /7,,)(!) CIVIL TERM
PROTECTION FROM ABUSE
WILLIMt II. TRITI, JR.,
Defendnnt
AND NOW, this
TEMPORARY PRCYn;;c'r I ON ORI>F.R
title
day of Apr i I.
1995. upon presentnt ion nnd
consideration of the within Petition, and upon finding that the plaintiff,
Barbara A. Swan, now residing at Shippensburg Mobile Estates, Lot 66,
Shippensburg, Cumberlllnd County, Pennsylvnniu, is in immediate nnd present dnnger
of abuse fromthedefendnnt, Williamll. Tritt, .Ir., the following Temporary Order
is entered.
The defendant, William II. Tritt, Jr., (SSN: 207-54-9881)(Date of Birth:
9/20/65) now residing at 48 Horse Killer Road, Shippensburg, Cumberlnnd County,
Pennsylvania, is hereby enjoined from physically abusing the plaintiff, Barbara
A. Swan, or placing her in fear of abuse.
The defendant is ordered to stay away from the plaintiff's residence
located at Shippensburg Mobile Estates, Lot 66, Shippensburg, Cumberland County,
Pennsylvania, a residence which is owned solely by the plaintiff.
The defendant is ordered to refrain from having any direct or indirect
contact with thc plnintiff including, but not limited to, tclcphone and written
commun i ca t ions.
The defcndant is enjoined from harassing llnd stalking the plaintiff and
from hnrllssing the plaintiff's rclatives.
The defendl1nt is cnjoined from cntcring the pll1intiff's place of
employment.
The defendant is enjoined from removing, dumnging, destroying or sell ing
uny property owned solely by the pluintifr.
A violllt ion of this Order mllY subject the defendant to: i) IIrrest under 23
PII. C.S. 66113; ii) /1 privllte criminlll complllint under 23 PII. C.S. 66113.1; iii)
II chllrge of indirect criminlll contempt under 23 Pa. C.S. 66114. puniBhllble by
imprisonment up to six IIIOnths IInd II fine of $100.00-$1,000.00; IInd iv) civi I
contempt under 23 1'11. C.S. 66114. I. ReBumpt ion of co-residence on the pnrt of
the plllintiff Ilnd defendllnt shall not null i fy the provisions of the court order.
This Order shull remuin in effect unt i I modified or terminated hy the Court
after not ice or hearing and, can be extended beyond thut time. if the Court finds
that the defendant hus committed another act of abuse or has engaged in a pattern
or pructice that indicntes continued risk of hllrm to the plaintifr.
This Order shall remain in effect unt i I modi fied or terminated by the court
after notice or hearing. A hellring shall he held on this muller on the / .J?{
dllY of Apri I, 1995, at ~: 30 /'J .m., in Courtroom No. l-l , Cumberland County
I -I-
Courthouse. Carlisle. Pennsylvania.
The plaint i ff muy proceed wi thout pre-payment of fees pending a further
order after the hear ing.
The Cumberland County Sheriff's Depurtment shall attempt to make service
at the plaintiff's request ancl wi thout pre-puyment of fees, but service may be
accompl ished under any appl icahle rule of civi I Procedure.
This Onler shill I he docketed in the office of the Prothonotary and
forwanled to the Sheri ff for service. The Prothonotary shall not send a copy of
this Order to the defendunt by mui I.
The Pennsylvania State Pol ice uncI the Mid-Cumherhmd Valley Regional Pol ice
Department will be pl'Ovided with certified copies of this Order by the
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plnintiff's attorney. This Order shall be enforced by any lnw enforcement agency
where a violation occurs by arrest for indirect criminal contempt without warrl.lnt
upon probahle cuuse that this Order has heen violated, whether 01' not the
violation is committed in the presence of the pol ice of ricer, In the event thut
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un arrest is made, under this section, the defendant shull be tuken without
unnecessary delay before the court that issued the order. When that court is
unavai lable, the defendant shall be tnken before the npproprinte district
justice. (23 P.S. ~ 6113).
By the Court,
,40
PI-
Judge
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BARBARA A. SWAN,
IN THE COURT OF COMMON PLEAS OF
PllIint iff
CUMDERLAND COUNTY, PENNSYLVANIA
v.
NO. 95-
CIVIL TERM
WILLIAM H. TRIIT, JR.,
Defendant
PROTEL'TION FROM ABUSE
NOTICE
You have been sued in court. If you wish to defend agninst the claims set
forth in the following pages, you must tnke /lct ion promptly after this Pet i t ion,
Order and Notice nre served, hy lIppearing personnlly or by attorney at the
hearing scheduled by the Court IInd present ing to the Court your defenses or
object ions to the c1l1ims set forth ngninst you. You arc wllrned thllt if you fai I
to do so the Court may proceed wi thout you, nncl n judgment may be entereclagainst
you by the Court wi thout further not ice for any money clllimed in the Pet i t ion or
for any other claim or relief requested by the plaintiff. You may lose money or
property or other rights importnnt to you.
FEFAe; AND COSTS
If the case goes to hearing and the judge grunts a Protect ion Order, a
surcharge of $25.00 wi II be assessed ngainst you. You may also be required to
pay IIttorney fees to Leg/ll Services, Inc. for their representation of the
plnint i ff.
You should take this parer to your lawyer at once. If you do not have a
lawyer or cannot nfford one, go to or telephone thc office set forth below to
find out wherc you can get legal help.
COURT ADMINISTRATOR, 4th FLOOR
CUMBERLAND COUNTY COURTIIOUSE
CARLISLE, PF..NNSYLVANIA 17013
TELEPHONE NUMBER: (7 I 7) 240-6200
AMERICANS Wll~ DISABILITIES ACT OF 1990
The Court of Common Pleas of Cumberland County is required by lllw to comply
with thc Americans with Disllbilitics Act of 1990. For information about
IIccessible faci lit ies ami rensonllb Ie lIccommodat ions avai lable to disabled
individullls hflving business before the court, please contact our office. All
IIrrangements must be mllde at least 72 hours prior to any hearing or business
before the court.
lIy the Court:
Date
Judge
BARBARA A. SWAN ,
IN TIiE COURT OF COM.\tON PLEAS OF
Plllint iff
ClJt,UlERLAND COUNTY, I'ENNS\1.VANIA
v.
CIVIL TERM
NO. 95-
WILLTAM H. TRITT, JR.,
Defendant
PROTECTION FROM ABUSE
PETITION FOR PROTF.CTION ORDI!R
RELIEF UNDER TIm PR01T..c'I'TON FROM ABUSE
ACT, 23 P.S. g 6101 et seq.
A. ABUSE
1. The plaintiff, BarbaI'll A. SWlln, is an Ildult individual residing at
Shippensburg Mobile Estates, Lot 66, Shippensburg, Cumberland County,
Pennsylvania 17257.
2. The defendant, William II. Tritt, Jr., (SSN: 207-54-9881)(Date of
Birth: 9/20/65), is an adult individual residing at 48 Horse Killer Road,
Shippensburg, Cumberland County, Pennsylvania, 17257.
3. The defendant has had an intimate relationship with the plaintiff.
4. Since approximately MIlY, 1993, the defendant has attempted to cause
and has intentionally, knowingly, or recklessly caused bodily injury to the
plaintiff, has plnced the plnintiff in rensonable fear of imminent serious bodily
Injury, and hns knowingly cngaged in II course of conduct or repeatedly committed-
acts toward the plnint i ff including following the plaint I ff wi thout proper
authorizntion, under circumstllnccs which have placed the plaintiff In reasonable
fear of bodi Iy injury. This has included, but is not I imlted to, the following
spec! flc instllnces of nbuse:
a. On or about March 20, 1995, beginning at approximately 12:30
a.m. the dcfendant telephoned the plllintiff's home repeatedly
despi te her request thllt hc not call her. The defendant continued
to call and hang up the telephont! or leave messages on the
plnint iff's nnswering mnchine. The defendnnt then drove hy the
plainti ff's home. The plnint iff feared for h..r safety and contacted
the Mid-Cumberland Valley Regionul Pol ice Depurtment regarding this
and prior incidents. The pol ice fi led charges ugninst the defendnnt
for hnrassment and stalking. A hearing on the charges wns scheduled
before District Justice Daihl on March 27, 1995. but the defendant
did not uppeur. A hearing wns rescheduled for April J, 1995, and
the charges were bound over to court.
b. On or about March ]9, 1995, at approximately J:OO a.m. the
defendunt telephoned the plaintiff's home several times. At
approximntely 4:45 p.m. the defendant came to the plaintiff's place
of employment and tried to get in to see her, but the manager
refused to let him in at the plaintiff's request. Later in the
cvening the defendant again telephoned the plaintiff's homc several
times.
c. On or about March 18, 1995, the defendant telcphoned the
plainti ff's home several times, had his mother tclephone the
plaintiff's home approximately 13 times throughout the day to get
her to talk to him. Latcr in the day the defendant drove by the
plaintiff's home.
d. On or about .lnnunry 23, 1995, the defendant grabbed the
plnintiff by her nrRls when she tried to leave his home, pushed her
to the floor, held her down by pinning her arms with his knees, and
choked her. The plnintiff cried nnd pleaded with defendant to let
her go und when she reminded him that he had promised her he would
not physically nhus.. ngain, he thrcntcned her saying, "Well, I'll
kill you nnd you won't hnve to worry ubout it." The plnintiff
feared for her life.
e. On or Ilbout September 5, 1994, the defendunt grabbed the
plaintiff hy her nl'ms, threw her onto the couch, hit her in the head
with a pillow severnl times, nnd pulled her hair.
f. In or Ilhout Octoher, 1993, the defendant stood in the doorway
of his home and shot n hllndgun repeatedly ns the plaintiff backed
her vehicle out of his drivewllY. The plaintiff feared for her
sufety.
g. In or ahout late summer, 199.1, the defendant broke the
plllinliff's windshield with his fist as she sat in her vehicle. The
plaintiff, fearing for her safety, drove aWIlY.
h. In or ahout the summer of 199.1, the defendnnt, brandishing u
puir of scissors, cut off a lock of the plnlntiff's hair. and
threutened to cut nil her hair off. The plaintiff feared for her
safety.
I. Since approximately MIlY, 1993, the defendant has abused the
plaintiff in wnys inclUding, but not limited to grabbing, pushing,
shoving, choking, restraining the plaintiff and pulling her hair.
In addition, the defendnnt used his vehicle to block the plnlntiff's
vehicle so she could not leave.
5. The plaintiff hel ieves and therefore flvers that she is in ill'mediute
and present danger of abuse from the defendant and that she is In need of
protection from such ahuse,
J. Ordering the defendant to refrnin from hnrass ing and
stalking the plnintiff nnd from hnrnssing the pJnintiff's
relntives;
4. Prohibiting the defendnnt from entering the plaintiff's
place of employment;
S. Prohibiting the defendant from removing, damaging,
destroying or selling property owned solely by the plaintiff;
6. Ordcring the defendant to stay IIwny from the plllintiff's
residence located at Shippensburg Mobile Estates, Lot 66,
Shippensburg, Cumberland County, Pennsylvania, which the
parties have never shared, and
7. Ordering the defendant to stay away from any residence
the plnint i ff may in the future establ ish for herse If.
B. Schedule a hearing in accordance with the provisions of the
"Protect ion from Abuse Act," llnd. after such hear ing, enter nn order to be in
effect for a period of one yenr:
I. Ordering the defendnnt to refrain from abusing the
plaintiff and/or placing her in fear of abuse.
2. Ordering the defendant to refrain from having any direct
or indirect contact wilh the plaintiff including, but not
I imited to, telephone IInd written communications.
J. Ordering the defendnnt to refrain from harassing and
stalking the plnintiff IInd from harassing the plaintiff's
relatives.
4. Prohib;ting the defendant from entering the plaintiff's
place of employmcnt.
5. Prohibi t Ing the defendunt from removing, dumnging,
destroying or sell in!' property owned solely by the plaintifr.
6. Ordering the defendnnt to stay away from the plnintiff's
residence located Ilt Shippensburg Mobile I~states. Lot 66,
Shippensburg, Cumherlund County, Pennsylvania, which the
part les have never shured.
7. Ordering the defendant to stay away from lIny residence
the plaintiff may in the future establish for herself.
8. Ordering the defendant to pay reasonable attorney fees
to Legal Services, Inc.
The plaint iff further asks that this Pet it ion be fi led and served wi thout
payment of fees and costs by the plllintiff, pending a further order at the
hearing, and that certified copies of this Petition and Order be delivered to the
Mid-Cumberland Valley Regional Pol ice Oepartment who has jurisdiction to enforce
this Order.
The plaint i ff prays for such other re I ief as mllY be just nnd proper.
Respectfully submitted,
~-
Attorney
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LFnAL SERVICES, INC.
8 Irvine Row
Carlisle, PA 17013
(7171 243-9400
The above-named plaintiff, Barbara A. Swan, verifies that the statements
made in the above Petition are true and correct. The plaintiff understands that
false statements herein are made subject to the penalties of 18 Pa. C.S. g 4904
relating to unsworn falsification to authorities.
Date:.-1 do rps/
.J
-,
8. The defemlllnt, although entering into this Agreement, docs not IIdmit
the IIllcSlltions made in the Petition.
9. The dcfendant understands thllt the Protcction Order entered in this
mlltter wi II be in effect for 1I period of one (I) year lind, can be extended beyond
that ti'lle, if the Court finds that thc dcfcndllnt hlls committed lIn lIct of lIbuse
or hlls engaged in II (mttero 01' prllct ice that indiclltes risk of 11lIrm to the
plaint iff on a cont inued basis. The defendllnt understands that this order wi II
be cnforcellble in the slime mllnner liS the Court's prior Temporary Protection Ordcr
entered in this case.
10. Violat ion of the Protect ion Order may subject the defcndllnt to: i)
IIrrest under 23 Pa. C.S, g6l13; i i) a privatc criminal complaint uncleI' 23 Pa,
C.S. g6113.1; iii) a charge of indirect criminal contempt under 23 PII. C.S.
g6114, punishable by imprisonmcnt up to six months Ilnd a fine of $100.00-
$1,000.00; and iv) civil contempt under 23 Pa, C.S. g6114.1.
~1fEREFORE, thc pllrt ics request that a Protect ion Order be entered to
reflect the above terms.
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William H. Tritt, Jr., Defendant
arbllra A. Swa
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'At torney for Plaint i ff /
LooAl. SERVICES, INC.
8 Irvinc Row
Carlisle, PA 17013
(717) 243-9400