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Home My WebLink About95-03145 [,1611 InlUllG Pot it loner IN 'nm COUHT 01' mt-lflON PLEIIS OAUI'IIlN COUNTY, PENNSYLVANIA v. No. i1/-ItJ4 S 1995 1INOREM L. REYES Respondent CIVIL IICT10N-LII\~ PROTECTION FHa-I 1II1USE PETITION FOR RELIEF UNDER TIlE PHOTECTION mOM ABUSE Acr TO TIlE llONOHABLE, Tim JUDGES 01' 'TIlE SAID mUHTI The Pet it ion of 1,1511 !DRING attorney, Kevin J. Lm~rence, Esquire, pursuant to Abuse Act, 23 Pa. C.S. Sections 6101, et seq., as represents as follows I 1. Petitioner Is an adult Individual presently residing atl 1707 Bridqo Street, New CII11berland, I'll 17070 ( ) or at an undisclosed address [or their protection, hereinafter referred to as "residence". , by his/her the Protection From amended, respectfully 2. TIle He6pondent is an adult Individual residing atl 1707 Dridqe Street, New OJIlberland, 1'A 17070 3. ~ty relationship l~lLh the Hespondent is (Husband/l~lfe, parent/child, boyfrlend/glrlfrlend/ex-girlfrlend, sexual/lnt Imate partner, etc.) 4. Pet it loner 2nd st., l!bg, PII Ex-IXlyfricnd Is employe,1 at 1Iealth Feadl 1Iam Care & Ilospice, l~lLh weekly earning of ~ 19.50/11r. . 205 8. 5. Hespondent is employed at PIlEM, 7th St., l!bg, I'll (Collections ~p;tr\) . 1~lth I-'Cekly earnings o[ ~ 7.75/1Ir. . -sel'\J~ 6. The residence I am lIsklng lhe Court to order the Hespondent to leave Is o.med/rentet\ in the name of Petitioner and her sister . 7. The Ilespondent lInd I (Ire tho pnrcnta of tho f{)llO\~lng minor child/ren I~ho presently live wlLh Petitioner I Nllme(s) IIgc(e) Nnmc(s) IIge(s) KellneUl 11. Feyes wring 11/5/93 8. Hespondent hnn enl\ilt\ed In abusive conduct tOlmrd Petitioner as such conduct Is defined In tIe Act. Examples Include, but are not limited to, the fol1O\~lnl\l a. b. On or aboul: ,1lUIO 2, 1995, Potitionor had a 101: of papoTh'Ork to do at work and Hospondont Cil110d hor up and said he was gotting off at 4100 p.m. Petitionor said be l'oady because I have a lot of paper- \>X)rk to do alld I1ospondenl: stated I can he off al: 3130. Petitioner went l:o pick up Hcmpondent and was 1 al:er UlOll 3130 due to a phone call. She arrived at PIU'M al: 3:40 ilnd waited fOl: 10 minutes, UlOn she left and went to v.urk. I'espondent walked to where Petitioner works ilnd had her pa<Jod. Hospondenl: \~as angry and Uley had a few words. Ibspondent had walked OUI: the door WiUl UlO baby and Petitioner did not want UlCln to walk across Ule ScUUl Bridge. Petitioner tried l:o take UlO baby back and Hespondent kicked Petitioner in her right thigh and nbovc her loft knee. . c. In t:cceJriJcr, 1994, Ibspondent tlu'eatened to beat UlO crap out of Petitioner. Petitioner is held prisoner 1.n her !MIl ham. Petitioner is in fear of her Ii fe. 9. As a con6equence of the above, Petitioner is afraid of Respondent and believes that he/she Is in inunedlate and present danger of further abuse and harassment from her/him. Further, Petitioner Is in need of, entitled to, and desires protection fran such abuse. 10. Pet I t10ner does not h,we Informat Ion concerning other litigation rogardlng the custody of the parties' minor children In this or another court. 11. Pet it loner, who has beeD the chlld's/chlldren pr Imary caretaker since birth ,believes tlh1t It Is In the child's best interest and \~e1fare that he/she be granted custody of him/her, WHEREFORE, pursuant 10 the Protection From Abuse Act, Petitioner prays your honorable court tot 1. lnunedlately enter a temporary order, and after hearing, a final ordeq A. Directing Respondent to refrain from approaching, abusing, harassing, or threatening Petitioner, either physically or verbally, wherever he/she IIUY llel B. Evict Ing Hespondent from 1707 Bridgo Streot, Now curr4Jer1and, I'll -;-placlng such residence In the exclusive possession /lnd contTo1 of the Petltloneq C. Excluding lleBpondent from Petitioner's current residence and any residence \~hlch he/she or the minor child/children may occupy Hhlle thla Order remains In effectl D. AllOlllng llespol1llent or Petitioner to (X!ncefully retrieve his/her personal possessions Illth the old of .1 local lrl\l enforcement officer, sold officer to be compensated, If compensation Is required, by llespondentl E. Prohibiting lleapondent from havlnl~ nny CODtoct Hlth Petitioner, Including telephone or other\4lse, except t lrough his/her attorneys I F. domest Ic or Court party. G. Prohibiting llespondent from stalking Petitioner as that term Is defined in the Crimes Code, 18 Pn. C.S. Section 27091 Directing that my confldentlal address and/or that of any violence progrnm not be disclosed by nny 11114 enforcement agency personnel to the respondent, respondent's counsel, or any third II. Directing Respondent to refralD from harassing communication Hith PetitioDer's relatives 1 I. Directing llespondent to relinquish Immediately any firearms or Ilea pons he/she may OIm, possess, or control, to the Dauphin County Sheriff upon being served here\4ith, and be prohibited from acqulriDg any other firearms or Ileapons throughout the duration of this Order. J. Granting such further relief as the Court deems appropriate. II. After hearing to be held Ilithln ten (10) days of the filing hereof, and pursuant to Section 1 of the Act, 23 I'a. C.S. Section 6708, enter a final protect ion order continuing the relief set forth above, for a period of one (I) year, and further requiring that Respondent I A. PursuaDt to subparagraph 5(d) of the Act, 23 I'a. C.S, Section 6707(D) , pay all taxable costs of this action, B. Pay attorneys fees for the use of the County of Dauphin In the amouDt of $250.001 C. Pay Petitioner $ N/A per Heek for the support and care of herself and the minor child until a final Order of Support Is entered by Domestic llelatlons, Illth said amount allocated as $ N/A spou6al support and the remaining $ IliA as child support. Respectfully submit ted, BY, Ib -I '.. .... -i~~rencet Esq. DATE I 6/8/95 ( ) 6. n1C~ follOl~lng mldltlonlll rellef IR hereby grllntedl 7. Respondent Is hereby notIfied that If he vlolateR thlR Order, he may \Jo held In Indirect crlmlnill contempt IIhlch Is punishable by a finD not to excced $1,000.00 lInd by a senlence of up to six months In jnll lmd by other possible rellef. Consent of Petitioner to reDlIllO contnct with RespoDdent shall not Invalidate thiB Order. 8. 1111s Order shall \Jo enforced by any Im~ enforcement agency In a county \~here 11 vlolntion of this Order occurs IIlthlD the CollUl1onwealth of Pennsylvllnlll. 9. A certified COl'Y of this Order shall be served on the po'.lce department(s) in t 1e jurlRdiction \~here Petitioner resides and Is employed. A certified copy of this Order shall llIUI1edlately be filed in the police county registry of Protection Orders. ( ) 10. The Sher Iff lInd the Prothonotary are directed to accept, serve and file any and all copies of this Petition and Order without prepayment of costs. 11. This Order shall remain in full force llnd effect until further Order of the Cour t. 12. A hearing is scheduled for the _d3 day of June , 1995 at 9; (J{) ~.N., in Court Room No. ~~r~~u~~~n County ~ourt Hou6e, Front and Narket Streets, '.~ _ n__~:1 ~ Hlt(.)" Ilnll.hy 1!PI\ofy tllI.lflll! "'rll'I"lr!(ll~~ ~ lr. .. ,,'J ';UII""! "j~tf. I)t ,," ')I,\'pllal Ii,d. " \ , , , . J. 'r' \ . ~ ,I ,\ f', ," (( I I .\.- II o I silt lllUTI 00 I Pet It iODer Respondent Sher If f Dauphin County flnergency NanagemeDt, Attentlonl Hoy Hyatt New CUrrberllltld Police Dep.1rtment 'PAIU<J~:fSutio; Police Department TIllS IS AN ORDm ()(o' romT. ANY VIOLATHJf OF TIllS mom SIIALL OONSTIT\ITE OONTDII'T O~' OOlJRT AND HAY BE I'UNISlIABLE BY A FINE UP TO ~1 ,000 AN\l/OO A JAIl. SENTlllia~ OF III' ro SIX (6) ~NTlIS. '...~ ''l ~ >- ~ . .- r-: .. ,... I' ::- .t ,.. a:: . ' N 11'1 ~ ~ .. .q ;:} "'( (~ \,-.,::. ,:'\f . :'i ~.. fo,l)iJ:i ;r-Hi' <~. ., 'H'_" .! I ,..;-. . l . " . .-'" , ,,~ \,') , - Ie. ,. ' '. ~ j < , . ., ,", ...,. ~ .. .. r - N N p w ti; fA