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HomeMy WebLinkAbout95-03233 ~ j . -7 ..-- "1 6 ~ j {11 (1S rn ~ Donna Mull, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 95-,!..J? ,'CIVIL TERM PROTECTION FROM ABUSE Plaint i ff v. Darrell Goodrich, De fendant AND NOW, t his TfMPQRAflY Pfl9UQT I_9NQRllER lS-<<' day of June, 1995, upon presentation and consideration of the within Petition, and upon finding that the plaintiff, Donna Mull, now residing at 1550 Williams Grove Road Lot 123, Mechanicsburg. Cumberland County. Pennsylvania, is in immediate and present danger of abuse from the defendant, Darrell Goodrich, the following Temporary Order is entered. The defendant, Darrell GOOdrich, SSN: 191-52-9655 and DOB: 8-12-65 now residing at 1225 Peffer Road, Mechanicsburg, Cumberland County, Pennsylvania, is hereby enjoined from physically abusing the plaint iff, Donna Mull, or placing her in fear of abuse. The defendant is ordered to stay away from the plaintiff's residence located at 1550 Williams Grove Road Lot 123, Mechanicsburg, Cumberland County, Pennsylvania, a residence which is leased solely by the plaintiff. 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 removing, damaging, destroying or selling any property owned jointly by the parties or owned solely by the plaintiff. A violation of 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. 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 risk of harm to the plaintiff. This Order shall remain in effect until modified or terminated by the court after notice or hearing. A hearing shall be held on this matter on the c~..i...:..-L day oU'/~'995, at J"I.~'- It .m., in Courtroom No.:;~, Cumberland county Courthouse, Carl isle, Pennsylvania. The plaintiff may proceed without pre-payment of fees pending a further order after the hearing. The Cumberland County Sheriff's Department shall attempt to make service at the plaintiff's request and without pre-payment of fees, bul service may be accomplished under any applicable Donna Mull, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY. PENNSYLVANIA v. NO. 95- CIVIL TERM Darrell Goodrich, Defendant PROTECTION FROM ABUSE NOT ICE 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 fai 1 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. F!;'E6 ANDCQ!H~ 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 AMERICAN!? \'11TH DlsAIHlITH!LACI Qf !!H1Q The Court of common Pleas of Cumberland County is required by law to comply with the Americans with Disabl1ities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled Individuals havin9 business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business bsfore the court. You must attend the schsdu1ed conference or hearing. a. 011 or about May 12. 1995, the defendant became angry wIth the plaintiff, grabbed the plaintiff by the back of the hair and threw her face down on the floor. The defendant then slapped and punched the plaintiff while rocking her head back and forth and grabbing the back of her hair. b. On or about May 21, 1995, the defendant grabbed the plaintiff by the back of her hair, threw her face down on her bed, and lay on top of her so that she could not move. When the plaintiff managed to wiggle away from the defendant, he became angry, grabbed her hair and threw her back on the bed with enough force to break the bed. The plaintiff again managed to free herself from the defendant and ran outside. The defendant ran after the plaintiff and pUShed her face down on the front seat of his truck. The defendant then put both of his hands around the plaintiff's neck and choked her. When the plaintiff was able to get away, she went toward the trailer to avoid further abuse. The defendant followed closely behind the plaintiff and slapped her in the back of the head several times. c. On or about June 11, 1995, the defendant became angry with the plaintiff, grabbed her hair and pUlled the plaintiff's head back so that she was facing a door jam. While the defendant held the plaintiff's head back, he threatened that he would smash the plaintiff'e face into the door jam. The defendant then pushed the plaintiff face down onto the floor. The plaintiff tried to get up repeatedly, but the defendant continued to push her back down onto the floor. When the plaintiff finally was able to get up, she grabbed the phone to call for help. The defendant grabbed the phone from the plaintiff and choked her. When the plaintiff got free, she picked up her son and ran to the front door. The defendant stood in the front door blocking the plaintiff's way. The plaintiff then ran out the back door with her son and the defendant ran after her. The plaintiff quickly ran back inside her trailer, locked all the doors and called 911 while the defendant pounded on the doors outside. The defendant left the plaintiff's trailer but returned several times and pounded on the back door. When the Carlisle State Police arrived, the defendant left, but they apprehended him and charged him with simple assault and harassment. 6. The plaintiff desires that the defendant be prohibited from having any d1rect or indirect contact with the plaintiff including, but not limited to, telephone and written communications. 7. The plaintiff desires that the defendant be enjoined from harassing and stalking the plaintiff, and from harassing the plaintiff's relatIves. 8. 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. a. ^TTQRN~Y F~~S 9. 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. II 6101 ~J !Htll., 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 end placing her In fear of abuse; 2. Ordering the defendant to refrain from having any direct or Indirect contact with the pleintiff 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. 4. Prohibiting the defendant from removing, damaging, destroying or selling property jointly owned by the parties or owned solely by the plaintiff; 5, Ordering the defendant to stay away from the plaintiff's resido~ce locoted at 1550 Williams Grove Road Lot 123, Mechanicsburg, Cumberland County, Pennsylvania; 6. Ordering the defendant to stay away from any residence the plaintiff may in the future establish for herself: B. Schedule a heari~g in occordance with tho provisions of the "Protection from Abuse Att," and. after such hearing. enter an order to be in effect for a period of one year: 1. Ordering tho defe~dant to refroin from abusing the plaintiff and p10cing her in feor of abuse. 2. Ordering the defendant to refrain from having any direct or indirect contact with the plaintiff including not limited to, telephone and written communications. 3. Ordering the defendont to refrain from harassing and stalking the plaintiff and from harassing the plaintiff's rslatives. 4. Prohibiting the defendant from removing, damaging, destroying or selling property jointly owned by the parties or owned solely by the plaintiff. 6. Ordering tho defendant to stay away from the plaintiff's residence located at 1550 Willaims Grove Road Lot 123, Mechanicsburg, Cumberland County, Pennsylvania. 6. Ordering the defendant to stay away from bny residence the plaintiff may in the future establish for stat&ments made in the above Petition are true and correct. The above-named Plaintiff, DONNA L. MULL, verifies that the Plaintiff understands that false statements herein are made SUbject to the penalties of 18 Pa. C,S. 04904, relating to unsworn falsification to authorities. /,' '/'.- Date: ~-bj_ _ , Q, / ' /'-I,,,,, I lIlt Donna L. Mull ( Plaintiff ) V l' {, F hEld.^ td I,'!' 'i' ilint }J; _r~^'ifUl~y1viHt t fl'..!: fjit ~ftt;t1.v~d_\.h~_*- r 'f, r l t t,f' ,'1 I1ml";;, "Ii t l,p M1f !l1,LL .IJ1J ~;(m ..LUil'li!HLIH'. i')! 'i i 11 !, fA (tlrH1.l':.hkAHQ..... ,. .,.. I.' I, II,' I I nl" '" b,. hond In'! \., I;!\n.~.j;l,\.. f}QQPHH:ll.. ..... '.. ".. . ".,.. ". H. , ,. ",.; ,.' l,;',\"d <:"I'Y t,d Hn, J'J)\)1f:FnI]lLfml!t.M1y.?f:.._..__..._____~~_ .; I . 1.<. ~ '.lmeLltl\(? ~h l'(;~(:t:ltlg JLut ti'.._tf'tl1_1t:HI to t:hE_-,l::n-l1tiE'ntelhtitffot. , 1 ! ;~- u;-! t. r~' : , 1-,,(1 riu ~tt#wi?fi- ~ 1 Hl. !:"l:l tl,,4~ , ,4", ~t\l~'" :,,1 1 ; j _;\' J i l._.l-QF" R~"-'Th!riiiJ:[i.'Krl-rij::'-J ".'1- i'i-} f' ij.:Jlf,"iH'i (~L' / iAf~ '"' ti \-' .11 ~~ b' >iI" ','~'_Q~:-L' t ,> i.i. \--J.<Jt....CI.)~,~~. ,~. Donna Mull, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 95-3233 CIVIL TERM PROTECTION FROM ABUSE Plaintiff v. Darrell Goodrich, De fendan t PROTfCTION O~PER AND NOW, this Z~rJ day of June, 1995, upon consideration of the Consent Agreement of the parties, the fOllowing Order is entered: 1. The defendant, DARRELL GOODRICH, 55:191-52-9655 and DOB: 8/12/65, is enjoined from physically abusing the plaintiff, DONNA MULL, or from placing her in fear of abuse. 2. The defendant is enjoined from having any direct or indirect contact with the plaintiff including. but not limited to, telephone and writlen communications. 3. The defendant is ordered to refrain from harassing and stalking the plaintiff and from harassing the plaintiff's relat ives. 4. The defendant is prohibited from removing, damaging, destroying or selling any Droperty owned by the plaintiff. 5. The defendant is ordered to stay IIway from the plaintiff'a residenca located at 1550 Williams Grove ROlld, Lot 123, Mechanicsburg, Cumberlllnd County, Pennsylvania. 6. The defendanl is ordered to stay IIway from /lny residence the plaintiff may in the future estllblish for herself. 7. The court cosla and fees ara waived. 8. Thill Order ahllll remain in affect for a period of one year or until modified or terminated by the Court after notice or hearing and may 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 risk of harm to the plaintiff. 9. This Order may sUbjoct the defendant to: i) arrest under 23 Pa. C.S. 66113; i i) 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. 10. The Pennsylvania State and lower Allen Township Police Departments shall be provided with certified copies 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 tho plaintiff may in the future establish for herself. 7. The defendant, although entering into this Agreement, does not admit the allegations made in the Petition. a. The defendant understands that the Protection Order entored in this matter shall be in effect for a period of one year or until modified or terminated by the Court after notice or hear i n9 and can be ex t ended beyond that time, if t he Court finds that the defendant has committed another act of abuse or has engaged in a pattern or practice that indicstes continued risk of harm to the plaintiff. g. The defendant understands that this Order shall be enforceable in the same manner as the Court's prior Temporary Protection Order entered in this case. WHEREFORE, the parties request that a Protection Order be to reflect the above terms. entered /1 'Do,fn;Mu~'l / Plai'n)t~if i,J~_. . 7~i!i~'!ey~~'~Lt- ------ Attorney for Plaint f LEGAL SERVICES, INC. a Irvine Row Carlisle, PA 17013 (717) 243-9400 (~~l~"'~'r~ck... ._______ J~I.O~~~~f'"d:~~~ Ha~. Ir in, III Attorney for efendan 36 B. Pitt Str Carlisle, PA 17013 (717) 243-6090 ~-" ,^-' .\., :"~ <,' ~t ~ '" -1. 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