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Home My WebLink About95-03059 . c o ";- ., .~ \(:X: 3 J j ~ Ji I , I I i I I { lA ~r. ~ ~11 a.;; U'tl:.I-. ~~a:~';,;, ~ "'-1;)\')-. 1.."1.::~,. t"Ilrr.. '_"l._ Z ..J ..~ < ,'. "" ,_I .~. ~V1 "Jl'o..i:.:z: La : .j,lt,2: Ur roh, ;: xu.. . ...." ~ 0" fI'\ ~ .... ~ ~ ~ ~ 'l e '~ .' ~ ;: " ~ ~ ~~ gj ~I 1m ~ ~ .., - ! ~ j j . ~ ~ ~ j ~ I ~ . I~ i~ j i I ~ j I!~ ~ ~ ~~ ''I-l . t'J8 i!S R 1(1 11111I to ~~ I ~, ~ it ~ ,. . . ; , . . , J UN G 1995clll, WAYNll F, SHAIlI' AllullIr)'al hw jlWull'umlrrISI1!;"fl ('IIIi.,t.I'rnn.)I........11 l7tlll TAMMY S. RUNYON, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW v. BLAINE J. BREAUX, Defendant No. 95-1 C' 'i'; CIVIL TERM PROTECTION FROM ABUSE AND NOW, TEMPORARY PROTECTIVE ORDER this L day of C1(ML of the within Petition I{,d upon consideration , 1995, upon finding that Petitioner is in immediate and present danger of abuse from Respondent, the following Temporary Protective Order is entered. Respondent is hereby enjoined from physically abusing Petitioner or placing her in fear of imminent serious bodily injury and is excluded from the residence of Petitioner at 1007 Forge Road, Carlisle (South Middleton Township), Cumberland County, Pennsylvania and from anyplace where Petitioner is working. Respondent is ordered to refrain from haVing any direct or indirect contact with Petitioner inclUding, but not limited to, telephone and written communications. Respondent is enjoined from haraSSing and stalking Petitioner and from harassing Petitioner's relatives. Respondent is enjoined from removing, damaging, destroying or selling any property owned jointly by the parties or owned Solely by Petitioner. This Order shall remain in effect Until a final Ordor is entered in this case. A hoaring shall be hold In this matter on 1Jw.w~ o'clock :&.M. ! ' f1L ,the .) day of ~l in Courtroom No. _/ June, 1995, at II: {iV , Cumberland County Courthouse, Carlisle, Pennsylvania. The Pennsylvania state Police will be provided with a copy of this Order by counsel for Petitioner 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 a polic~ officer. In the event that an arreet is made under this section, Respondent shall not be taken to jail, but shall be taken without unnecessary delay before the Court which has issued this Order. When the Court is unavailable, Respondent shall be arraigned before a District Justice who shall set bail according to the provisions of Chapter 4000 of the Pennsylvania Rules of Criminal Procedure. J. Wayne F. Shade, Esquire Attorney for Petitioner Blaine J. BreauK Respondent TAMMY S. RUNYON, Plaintiff IN TilE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW v. BLAINE J. BREAUX, Defendant NO. 95- ,(') '7 CIVIL TERM PROTECTION FROM ABUSE NOTICE You have been sued in Court. If you wish to defend ogainst the claims set forth in the following pages, you must take prompt oct ion after service of this Petition, Order of Court and Notice are served upon you by appearing personally or by legal counsel at the hearing scheduled by the Court and by 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 case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the pleadings or for any other claim of relief requested by the Plaintiff. You may lose money or property or other rights importont to you. YOU SHOULD TAKE TillS PAPER TO YOUR LAWVER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELO\~ TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Court Administrator Fourth Floor Cumberland County Courthouse Carlisle, Pennsylvania 1701J Telephone: (717) 240-6200 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reaeonable accommodations available to disabled individuals having business before the court, please contact the Court Administrator's office as noted above. All arrangements must be made at least 72 hours prior to any hearing or business before the Court. WAYN!! F. SUA"" ^"lllllC'Y II hw H Wull'lIl111rl Nlltt'l 1'lIl1d...,I't'IIIi1)lul1ill I7I1Il wa~~s~q-~ire Supreme Court No. 15712 53 West Pomfret street Carlisle, Pennsylvania 1701J Telephonol 717-24J-0220 Attorney for Petitioner WA\'NI' 1', SUAIII' AII'HlIc)' .11.... \IWr'II'lIll1hr' !illl'fl 1'.,hd"I'clulI)hlllia 1M' 'I'AMMY a. HUN YON , Plnintiff IN THE CUURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW v. NO. 95- 30~-'1 CIVIL TERM "LAINE J. "REAUX, Defendant PROTECTION FROM ABUSE PETITION FOR PROTECTIVE ORDER PROTECTION 1. Petitioner is an adult individual who resides at 1007 Forge Road, Carlisle, cumberland County, Pennsylvania 17013, and who is self-employed out of her residence. 2 . Respondent is an adult individual whose last known address is the address of Petitioner and whose present address is unknown but who may be staying at the Embers Motel at 1700 Horrisburg Pike, Carlisle, Cumberland County, Pennsylvania 17013. Respondent has been employed in Petitioner's business, so he cannot be served at his place of employment. Respondent is a white male, 41 years of age with dark hair, 5 feet 9 inches tall, weighing 200 pounds. Respondent drives a gray 1989 Nissan kin9 cab pick-up truck with a white cap and Louisiana license plats.. Petitioner does not know the license plate number. 3 . Petitioner and Respondent are unmarried but have liv.d together since 1991 in a relationship involving sexual relations WAYNH J'. SUAI>E Anumt)' al taw 'lWull',.nhfl Stlnl ('.,Ulk'. l'rnnl)'lvanla 171111 4 . Since 1992, Respondent has attempted to cause or has intentionally or recklessly caused bodily injury to Petitioner or has placed Petitioner, by physical menace, in fear of imminent serious bodily injury as a result of the following conduct: (a) On June 6, 1995, Respondent became upset with the teenage children of Petitioner and proceeded to take his frustrations out on Petitioner. When Petitioner went to leave for work, Respondent took the keys to her vehicle so that she could not leave for work. When Petitioner went to call the police, Respondent grabbed the telephone from her. Petitioner then ran in fear to the bedroom. She locked herself in the bedroom and called the police from the bedroom; (b) On or about February 9, 1995, Respondent became angry, came at Petitioner and shoved her with both hands in the chest, causing her to hit her back and head against a wall and fall to the ground. When Petitioner scrambled to her feet attempting to get to the phone, Respondent again shoved her forcefully into the wall and repeated this approximately two more times, causing Petitioner pain. When Petitioner was able to get to the phone, she called 911 and the police arrived and arrested Respondent. Petitioner was taken by ambulance to the Carlisle Hospital Emergenoy Room -2- where she was treated and released. Petitioner suffered soreness about her head and body; (c) On or about January 2B, 1995, Respondent came into the room, screamed at Petitioner, picked up Petitioner's rocking chair and slammed the rocker down onto the floor, smashing the chair's legs. Respondent then stomped his foot through the wicker seat of the rocker as well as the back rest and threw the chair out the door causing Petitioner to fear for her safety. Respondent then came at Petitioner, grabbed her by the shirt and, while holding her, grabbed a can of beer from Petitioner, crushed it and poured it over Petitioner's head. Respondent, glaring at Petitioner, stomped his feet in a rage. Petitioner, fearing for her safety, left the residence. When Petitioner returned, she was unable to locate her dog, but noticed blood on the carpet. Respondent admitted to Petitioner's fourteen year old son that he had killed the dog by stomping on it. Petitioner has been unable to locate her dog and feels that Respondent burned the dog's body in the wood stove; (d) Approximately once a month, Respondent backed Petitioner into walls, shook his finger in her foce and screamed at her, causing her to fear for her safety; (e) In or around July 1992, while the parties lived in Louisiana, Respondent threw Petitioner down onto the cement W^\'NI! 1', SII^IJI! Attut1ltf 1ll.lW HWnll'lIl1lrrtl~llrtl .',dlalc'.I'c'lIll1yh.lIi. 17Ul.l -]- in the carport. When Potitioner got up and tried to run, Respondent caught her and again threw her down onto the carport, pinned her down and choked her by placing his arm over her throat. Petitioner pretended to paes out so Respondent would stop. only then was Petitioner able to get away; (f) since 1992, Respondent has abused Petitioner in ways inclUding, but not limited to, grabbing, shoving, restraining and choking Petitioner. Respondent has broken Petitioner's possessions and thrown things around the room causing Petitioner to fear for her safety; and (g) As a result of these disturbances, the Pennsylvania state Police have been repeatedly summoned and havs indicated their inability to take action in the absencs of a Protective Order. 5. Petitioner believes and therefore avers that she will be in immediate and present danger of abuse from Respondent should he be permitted to be at the residence of Petitioner or at anyplace where she is working and that Petitioner is in need of immediote ex parte protection from such abuse. WHEREFORE, pursuant to the provisions of the "Protection from Abuse Act", 23 Pa.C.S. 56101, et seg., as amended, Petitioner prays that your Honorable Court grant the following relief: W^YNI! F, SIl^111! Allulllt)' .11..... UWulll,,*tthrl Stlnl ('lIh.lt,I"'IUlI)hlni.1 11111' -4- W~I'NI' Ii, SIl~111 "'""II.... .11_* H WUI"t.II'." HhlTI 1'1111''', l'I'IUl'~ I~"IUI '-/1111 (a) A Temporary Protective Order requiring Respondent to refrain from abusing Petitioner or placing Petitioner in fear of abuse and ordering Respondent to stay away from anyplace where Petitionor is working; (b) The scheduling of a hearing in accordance with the provisions of the "Protection from Abuse Act" and, after such hearing, the entry of an order, to be in effect for a period of one year, requiring Respondent to refrain from abusing Petitioner or placing her in fear of abuse; (c) Directing such further relief as authorized under 56108 of the Act including directing Respondent to pay f 1 Petitioner for reasonable losses suffered as a result of the abuse, including, medical, dental, relocation and moving expenses, counseling, loss of earnings or support and other out-of-pocket losses for injuries sustained and reasonable attorney fees; and (d) Such other relief as may be just and proper. EXCLUSIVE POSSESSION 6. The residence of Petitioner is owned by Petitioner. WHEREFORE, pursu'lnt to the provisions of the "Protection from Abuse Act", 2] P'l.C.S. 56101, et seq., as amended, r- -5- WArN/! F, SIlAIlI! AIIINnC'y Ill...", HWntl'1l1lllrrlHlml ('''lidr, "rMI)hllli' 17UII Petitioner prays that your Honorable Court grant exclusive possession of the premises to Petitioner. Wa~~h~~e Supreme Court No. 15712 53 West Pomfret Street Carlisle, Pennsylvania 17013 Telephone: 717-243-0220 Attorney for Petitioner -6- The statements in this Petition for Protective order are based upon information which has been assembled by my attorney in this litigation. The language of the statements is not my own. I have read the statemonts; and to the extent that they are based upon information which I have given to my counsel, they are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. e.s. S4904 relating to unsworn falsification to authorities. Date: June 6, 1995 T WA\'NI! 1', SHAIII! AlIlIUh')' II hw HWull'ullIflflhllt'cl ("IU_k. 1'''M.)I~.ni. PUll TAMMY S. RUNYON, Plaintiff IN TilE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW v. NO. 95- 3059 CIVIL TERM BLAINE J. BREAUX, Defendant PROTECTION f'fDER OF COURT ~ day of June, 1995, FROM ABUSE AND NOW, this it appearing that Plaintiff has been unable to locate Defendant for service, the hearing scheduled herein for Thursday, June 15, 1995, is rescheduled for Wednesday, June 28, 1995, at 9:00 A.M. in Courtroom No.3, Cumberland county Courthouse, Carlisle, Pennsylvania. The Temporary Protective Order issued June 6, 1995, shall remain in full force and effect pending the hearing. er, J. ,', I', " ::.- ,.f'., ..- "," I Wayne F. Shode, Esquire Attorney for Plaintiff Mr. Blaine J. Breaux Defendont t..'i'"' - ,.,. ....L,L il'/11o/9S- ~, ~), . , to. . .. r .} '.. "'0, 1'1. ,":,':? .... . ' -," ....-;" '. cs 4:- 'I ~ ::n . ,. - 0-, ~ , .' TAMMY s. RUNYON, Plointiff IN TilE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVI L ACTION - LAW v. tlO. 95- J059 CIVIL TERM BLAINE J. BREAUX, Defendant PROTEC'I'IOtl FROM ABUSE ~RDER OF COURT AND NOW, this~ day of June, 1995, it appearing that Plaintiff will require additional time to serve Defendant, the hearing scheduled herein for Wednesday, June 28, 1995, is rescheduled for Wednesday, July 26, 1995, at 91JO A.M. in Courtroom No. J, Cumberland County courthouse, Carlisle, Pennsylvania. The Temporary Protective Order iseued June 6, 1995, shall remain in full force and effect pending the hearing. r, J. Wayne F. Shade, Esquire Attorney for Plaintiff Mr. Blaine J. Breaux Defendant ('<'(t" " (l"".J.,.l -t,.. (ltJ.J ~.tL."/,Jo/9S' (~it. ",f~ "04,':t.. J...;....,~) ..1, f t _ 1;, "-J c:J c;:.~ 'II .J !a , , . t1t j. I;, . ;ll'110ji,;jl,..'j (,1 'Ii lli:li!1 I I : ~ ,1 l I' , \, \ \.\ ,',1; 1.,.;t. -I I Iii II '! v, L l' ...., If;.l' h' '"I!' -, i' " !l1.iT l'LHi 'I,!, \', Y 1,"1 Iii T" ,hId. 11\.,1,\: i\\ FE f d,. t: T HI i1':'!,: ~j , , !... , \! f" ! ; " ,1;,..1- '1( , . I' ;.. I \.)L.....'-" Lh''- O. -IIIU~1 "-at"'? " I, / ;,/ _ (,/v.; " -''/' - r', ~ ,_ ,'a' .. '-",., .' .i , ; i! , . " . ,,' , III TOU .ICIlII'f NOnPlID TO fill A ..."..1IUfQIM TO THlIIlCU*D . . W1t111lllWI"I'IIIOI DAYI ....IIMCI HlIIlCf 011 A lUDQIIIItT *",.lNlIIIlD ~ YOU. It l11llHY WAYNE F. SHADE WI DO HI my CaRYl.. THAt '"-t~ WllltIN IIA TII\lI AND COlIMOT OWY.hi Of THI ORIII"A~ flLlD IN .,11I,,, , Ae~. ~:~.U~J>J995~ lmWIlY ,__- ~ Al10llNIYAT LAW 53 WIlT POlolFJlT 51111" CAIUlll, PINNSYLVANIA 17013 , ... M . .. f ..... . .... -_. \ \ . ~- TAMMY S. RUNYON, Plaintiff IN 'l'IIE COUR'!, 01' COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVI L AC'l'ION - LAH v. 110. 9!:i- jo~"l CIVIl, TERM BLAINE J. BREAUX, Defendant PHO'l'EC'I'ION FROM ABUSE AND HOW, ccnsideration TEMPORARY PROTECTIVE ORDER ..A. this (j, day of ~.. '~..L , 1995, upon of the within Petition and upcn finding that Petitioner is in immediate and present danger of abuse from Respondent, the follcwing Temporary protective Order is entered. Respondent is hereby enjoined from physically abusing Petitioner or placing her in fear of imminent serious bodily injury ond is excluded from the residence cf Petitioner at 1007 Forge Road, Carlisle (South Middleton Townshipl, cumberland county, pennsylvanio and from anyplace where Petitioner is working. Respondent is ordered to refrain from having ony direct or indirect contact with Petitioner inclUding, but not limited to, telephone and written communications. Respondent is enjoined from horassing and stalking Petitioner and from horossing Petitioner's relatives. Respondent is enjoined from removing, damaging, destroying or selling any property owned jointly by the parties or owned solely by Petitioner. This order shall remain in effect until a final order is entered in this case. A hearing shall be held in this matter on WAYND F. SUAUI! AltotM)'all..w 51 w... romrrd IIlftl c..,U.", rnuuylVllIlI 11011 T~'~ o'clock ~.M. , the / s-:t!tdny of June, 1995, at II: c::lQ) in Courtroom Ho. ~ , cumberland county courthouse, Carlisle, I'ollllsylvilnia. 'I'he Pennsylvania titate police will be provided with n copy of this order by counsel for Petitioner and may enforce this order by arrest for indirect criminal centempt without warrant upon probable couse that this order hos been violated, whether or not the violation is committed in the presence of a police officer. In the event that an arrest is made under this section, Respondent shall not be taken to joil, but shall be taken without unnecessory deloy before the Court which has issued this order. When the Court is unavailable, Respondent shall be arraigned before 0 District Justice who shall set bail according to the provisions of Chapter 4000 of the Pennsylvania Rules of criminal Procedure. By the court, s:~, C'~, J. Wayne F. Shade, Esquire Attorney for Petitioner Blaine J. Breoux Respondent WAYNB F. SUAI"l AlII.JnV1t1l..w n Witt rom'rrt IU"I Ct.UaIe, rtM.~IYania 11011 'PAMMY S. RUNYON, Plaintif( IN TilE COUR'I' OF COMMON PI,EM OF CUM~ERLAND COUNTY, PENNSYLVANIA CIVI L ACTION - I,AI~ v. NO. 9!J- CIVIL 'I'EIlM BLAINE J. BREAUX, Dofondant PIW'I'EC'I'ION FROM ABUSE NOTICE You have been sued in Court. It you wish to defend against the claims set forth in the following pages, you must take prompt action after service of this Petition, Order of Court and Notice ore served upon you by appearing personally or by legal counsel ot the hearing scheduled by the Court and by presenting to the Court your defenses or objections to the cloims set forth against you. You are warned that if you fail to do so the case moy proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the pleadings or for ony other claim of relief requested by the Plaintiff. You may lose money or property or other rights important to you. 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, Pennsylvania 17013 Telephone: (717) 240-6200 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland county is required by law to comply with the Americans with Dieobilities Act of 1990. For information about occessible facilities and reasonable accommodations ovailable to disabled individuals having business before the court, please contaot the Court Administrator's office as noted above. All arrangements must be made at least 72 hours prior to any hearing or business before the Court. WAYNn 1', StlAlln Auumey .Il.... uw... rUIII,,,"I,,,1 .'''litle,'1mn.)Iw....I. 11011 wa~~S~~~ire Supreme Court No. 15712 53 West Pomfret Street Carlialo, Pennsylvania 17013 'I'elephonol 717-243-0220 Attornoy for Petitioner WAYNII F, SIIAllI! Aaumt)' 11 lAw U Wul pumr'd Blue'l ClfUd" I'tMI)'lvanl. 11011 TAMMY S. HUNYON, Plaintiff IN 'l'IIE COURT or COMMON PLEAS or CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW v. no. 95- ~C';'i' CIVIL 'PERM BLAINE J. DHEAUX, Dofendant I'HOTECTION mOM ABUSE PETITION FOR PROTECTIVE ORDER PROTECTION 1. Petitioner is an odult individual who resides at 1007 Forge Road, Carlisle, cumberland county, Pennsylvania 17013, ond who is self-employed out of her residence. 2. Respondent is an odult individual whose last known oddress is the address of Petitioner and whose present oddress is unknown but who may be staying at the Embers Motel at 1700 Harrisburg Pike, Carlisle, cumberland county, Pennsylvania 17013. Respondent has been employed in Petitioner's business, so he cannot be served ot his place of employment. Respondent is a white male, 41 years of age with dark hair, 5 feet 9 inches tall/ weighing 200 pounds. Respondent drives a gray 1989 Nissan king cab pick-up truck with a white cap and Louisiana license plates. Petitioner does not know the license plate number. 3 . Petitioner and Respondent are unmarried but have lived togethor since 1991 in a relationship involving sexual relotions. );-;, c-:l.~ :Ti$ ~~! -:;':~ .,..:; ,-.t -/1 , -~.~. ~ 4 . since 1992, Respondent has attempted to couse or has intentionally or recklessly caused bodily injury to Petitioner or has placed Petitioner, by physical menace, in fear of imminent serious bodily injury as a result of the following conduct: (a) On June 6, 1995, Respondent became upset with the teenage children of Petitioner and proceeded to take his frustrations out on Petitioner. When Petitioner went to leave for work, Respondent took the keys to her vehicle so that she could not leave for work. When Petitioner went to call the police, Respondent grabbed the telephone from her. Petitioner then ran in fear to the bedroom. She locked herself in the bedroom and called the police from the bedroom; (b) On or about February 9, 1995, Respondent become ongry, came at Petitioner and shoved her with both hands in the chest, causing her to hit her back and head against a wall and fall to the ground. When Petitioner scrambled to her feet ottempting to get to the phone, Respondent again shoved her forcefully into the wall and repeoted this approximately two more times, causing Petitioner pain. When Petitioner was able to get to the phone, she called 911 and the police arrived and arrested Respondent. Petitioner was taken by ambulance to the Carlisle Hospital Emergency Room WAYNe P. SIIAIJn Anome)' I' law U Weal rom(rt'1 Slfr~l (,..lillt, rmnl~IYlnu 11011 -2- where she wos treoted ond releosed. Petitionor sufforod soronoss obout hor hoad ond body; (c) On or about January 28, 1995, Respondent came into the room, scroamed at Petitioner, picked up Petitioner's rocking chair and slammed the rocker down onto the floor, smashing the chair's legs. Respondent then stomped his foot through the wicker seat of the rocker as well as the back rest and threw the chair out the door causing Petitioner to fear for her safety. Respondent then came at Petitioner, grabbed her by the shirt and, while holding her, grabbed a can of beer from Petitioner, crushed it and poured it over Petitioner's head. Respondent, glaring at Petitioner, stomped his feet in a rage. Petitioner, fearing for her safety, left the residence. When Petitioner returned, she was unable to locate her dog, but noticed blood on the carpet. Respondent admitted to Petitioner's fourteen year old son that he had killed the dog by stomping on it. Petitioner has been unable to locate her dog and feels that Respondent burned the dog's body in the wood stove; (d) ApproximatelY once a month, Respondent backed Petitioner into walls, shook his finger in her face and screamed at her, causing her to fear for her sofety; (e) In or around July 1992, while the parties lived in Louisiana, Respondent threw Petitioner down onto the cement in the carport. When Petitioner got up and trisd to run, WAYNe F, SIIAue Anomt)' 111...w - 3 _ 'J Wull'umrrrlSlIttl t'"llllr,l'tlllllylvanla I7l1ll WAYNC F, SIIAIlC Atlomt)' al ......w 51 Wi'll rUlnr". 8tml (,.,Ii,It, PrMI)'lnni. 17011 Rospondont caught hol:' and aqain thl:'ow her down onto the cal:'pol:'t, pinned hel:' down Dnd chokod hel:' by placing his arm over her thl:'oat. Petitioner pretended to pass out so Rospondent would utop. only then was Petitioner able to get away; (f) Since 1992, Respondent has abused Petitioner in ways including, but not limited to, gl:'abbing, shoving, restraining and choking Petitioner. Respondent has broken Petitioner's possessions and thrown things around the room causing Petitioner to fear fol:' hel:' safety; and (g) As a result of these disturbances, the Pennsylvania state police have been repeatedly summoned and have indicated their inability to take action in the absence of a Protective Order. 5. Petitioner believes and therefore avers that she will be in immediate and present danger of abuse from Respondent should he be permitted to be at the residence of Petitioner or at anyplace where she is working and that Petitioner is in need of immediate ex parte protection from such abuse. WHEREFORE, pursuant to the provisions of the IIprotection from Abuse Act", 23 Pa.C.S. 56101, et seq., as amended, Petitioner prays that your Honorable Court grant the' following relief: -4- tLI~f~ Wllyne '";j:'. Shade, Esquire supremo Court No. 15712 53 West Pomfret street Cllrlisle, Pennsylvania 17013 Telephone: 717-243-0220 Attorney for Petitioner Petitioner p."llYo that you." IlonOl:i\ble Cou.-t grllnt exclusive possession of the IH-clnioco to Petitioncl:. WAYNU p, SIIAlJl! AIlOmt)' III..W U WUI l'ulIltrrt atft'tl ('.,I"It.I'tMI)'lvanit 11011 -6- i I r r, Ii', I."; \' u II NOr " ",JJO HI "., - :i-;..; E ' .. l@~ ~'~", 1 ~ 1 '. -::::r" '" : ! ~ IT'") ",I N I~_ d h;; -=; " -. ~ ~ f' -i ~ ... . ~ j !I!) ~BlftS B ~~B R ~~ . Ii ~J uil1t ~ ~~ ~ I ,. , . I, I .. , . ~ .. . TAMMY S. RUNVON, Plointi ff IN TilE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSVLVANIA CIVIL ACTION - LAW NO. 95-J059 CIVIL TERM PROTECTION FROM ABUSE v. BLAINE J. BREAUX, Defendant ;WrCTlVE ORDER AND NOW, this ~~ day of July, 1995, upon consideration of the Consent Agreement of the parties, the following Order is entered I 1. Defendant is ordered to refrain from abusing plaintiff or placing her in fear of abuse or threatening her. 2. Defendant is ordered to refrain from harassing plaintiff. J. Defendant is enjoined from contacting Plaintiff wherever she moy be working. 4. Defendant is ordered to stay away from the residence of Plaintiff located at 1007 Forge Road, carlisle, Pennsylvania 1701J. 5. Defendant is ordered to stay away from any residence plaintiff moy in the future establish for herself. 6. Defendant is ordered to refrain from having any direct or indirect contact with Plaintiff including, but not limited to, telephone ond written communications. 7. Defendant is enjoined from harassing or stalking Plaintiff. B. This order shall remain in effoct for a period of six months. ~ . 9. The Penneylvania state Police will be provided with a copy of thie Order by counsel for Plaintiff 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 violotion is committed in the presence of a police officer. In the event that an arrest is made under this section, Defendant shall not be taken to jail, but shall be taken without unnecessary delay before the Court which has issued this Order. When the Court is unavailable, Defendant shall be arraigned before a District Justice who shall set bail according to the provisions of Chapter 4000 of the Pennsylvania Rules of criminal Procedure. By the court, J. ( Wayne F. Shade, Esquire - 4t'1'""J jU\M~q '}U~_ '1/,Lrifr Attorney for Plaintiff tI . ,;___ Joseph L. HitChings, Esquire ... t~ "'n~6,l Johnson, DUffie, stewart & Weidner 1/~t/~'- Attorneys for Defendant A<L....-- 0090900000llJuly 2', 1995/JLlI/MII/."OJ . , J AM MY S, RUNYON. IN TilE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO, 95-3059 CIVIL TERM j. i , Plaintiff vs, CIVIL ACTION. LAW BLAINE I, BREAUX, PROTECTION FROM ABUSIl Defen~ant CONSENT AGREEMENT TillS AGREEMENT Is entere~ on this ~ay of luly, 1995, hy an~ hetween Plaintiff, Tammy S. Runyon, an~ Defen~ant, Blaine I, Breaux, Plaintiff Is represented hy Wayne F. Sha~e, Esquire; and Defen~antls represente~ hy Joseph I., HIt~hlngs, Esquire, of lohnson, Durne, Stewart & Wel~ner. The parties agree that the following may he entere~ as an Or~er of Court: I, Defen~ant 15 or~ere~ to refrain frum ahuslng Plaintiff or placing her in fear of ahuse or threatening her, 2, Defen~antls or~ere~ to refrain frum harassing Plaintiff. 3. Defen~ant 15 enjoine~ frum conta~tlnllPlaintlff wherever she may he working. 4, Defen~antls urdere~ to stay awuy frum the resl~ence of Plalntlfflocated at 1007 Forge Roa~, Carlisle, Pennsylvania 17013, 5, Oefen~antls urdere~ to stay away from any resl~ence Plaintiff muy In the future estahllsh fur herself. 6, Oefen~unt Is ur~ere~ to refrain frum huvinll any dlrecl or In~lrect contact with Plaintiff Inclu~ing, hut nlltllmited to, telephllne alld written communlcatlllns, t I Defendant agrees \lIthe entry of the fnregnlng Or~er. Although entcrlng Into this Agrecment, Defen~ant ~oes nutudmlt uny allcllathllls Illillle In the Pctitlnn. . 00909000011l/July ~5, 199"JLIIIMlllmOJ , . D~f~ndant und~r"lands that the I'wl~ctlv~ Ord~r ~nt~r~'\lln this mailer shall he In effect for a period of six (6) munths, WIIEREFORE, the parlles requ~stthat a I'rul~ctlve Order he entered to r~nectlhe ahove terms. O~.u ~-l~ Wayne ,Shade Allorney tilr Plaintiff JOHNSON, DUFFIE, STEWART & WEIDNER ~.-1 A. ~ J eph L, Hitchings Allorneys for Defendanl