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HomeMy WebLinkAbout95-03898 ~ J . '" 7' tJ ';i ~ ~ F J ()o &; rY) ,."., ~.: <~ ,.):.: ,!", ,,>c..,', "'-'~YANIA'7013,; ".. ;'\ '''';':'''''''''-^ non. DO'..:..,..".... ->"< ~ t, .~ ,_,T, "~ir". <<'j , 'iN';"li...I7t712A31t :" . .,'. \,' "; 'l,\",..,:..:,.<. '''''c~:''\4': l~.'n: F8K17t7) 24..... '.. ' _, .,"\ ::',~~'" ?~'I;":,.'it-, . ,.:,,~,\..', '" .'",,- ' . :."'..' '" " " -'", >>-""~\' J:',C'A.',.'.; ';';';w.;.:'irilcn 17m ~,: '.',~ ".." "8"";:'0" '2' '19''''9'5,~o:, c-~~,,,~ l7t71ll3O n~L .~:.' AU. " . _, " .f.J!h~' 'V<' ".~",;-"<,:,, '.... ".: , , ... . . '-. -........,..- "":~...~~ - . r'-.l ORDER FOR CONTINUANCE '}1 "~ ::.i:: AND NOW, this ~ day of ~, 1995, upon ~ consideration of the attached Motion for continuance, the matter scheduled for hearing on July 31, 1995, at 8:45 a.m. in Courtroom No.5, by this Court's Order of July 24, 1995, is hereby rescheduled for the :. .f,[ day of ...1'.:.01.'" f /,.... .' 1995, at J :(JC r .m. in Courtroom No." The Temporary Protection Order will remain in effect for a period of one year or until a final Order is entered in this case. A certified copy of this Order for continuance will be provided to the Pennsylvania state Police Department and the Carlisle Police Department by the plaintiff's attorney. By the court, J Joan Carey, Esq, ATTORNEY FOR PLAINTIFF Ralph I'inskey, t:sQ, ATTORN~:Y FOR Imn:NDANT .Y . ,J I.' 'J.. L~ fl' j'r . f.I/..;' '!" . ,", 1.'1 'f; '....~-' tof...... "L(;~-<L!5h 1'1,) " A' . ~ SUZETTE M. STEELE, plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 95-3898 CIVIL TERM v. CHARLES M. LAUNSE, Defendant PROTECTION FROM ABUSE MOTION FOR CONTINUANCE The plaintiff moves this Court for an Order continuing the hearing 0 this case until further Order of Court, on the grounds that: 1. A Temporary protection Order was issued by this Court on July 24, 1995, scheduling a hearing for July 31, 1995, at 8:45 a.m. 2. The Dauphin county Sheriff's Department and the plaintiff have been unable to locate the defendant and serve him. 3. The plaintiff requests that a continuance be entered and that the Temporary protection Order remain in effect for a period of one year of until a final Order is entered in this case. 4, A copy of the Order for continuance will be delivered to the Pennsylvania State police Department by attorneys for the plaintiff. WHEREFORE, the plaintiff moves this court to grant the plaintiff'S Motion, and to continue this matter until further Order of court. ~)(" o,an carey Attorney for Plain iff LEGAL SERVICES, INC. a Irvine Row Carlisle, PA 17013 (717) 243-9400 '- r-, ~ (~, <:> -~l ~ ...., CJn Suzette M. Steele, IN THE COURT OF COMMON PLEAS OF Plaintiff v. : CUMBERLAND COUNTY, PENNSYLVANIA NO, 95-3&18 CIVIL TERM PROTECTION FROM ABUSE Charles M. Launse, Defendant AND NOW, this TEMPORARY PROTECTION ORDER day of July, 1995, upon presentation and consideration of the within Petition, and upon finding that the plaintiff, Suzette M. Steele, now residing at 708 Allen Road, Carlisle, Cumberland county, Pennsylvania, is in immediate and present danger of abuse from the defendant, Charles M. Launse, the following Temporary Order is entered. The defendant, Charles M. Launse, (SSN: 198-50-4278) (D.O.B.: 08/02/63) now residing at a location which is unknown to the plaintiff, is hereby enjoined from physically abusing the plaintiff, Suzette M. Steele, and from placing her in fear of abuse. The defendant is excluded from the plaintiff's residence located at 708 Allen Road, Carlisle, Cumberland County, Pennsylvania, a residence which is leased solely by the plaintiff and which the defendant has voluntarily left. 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, except for the limited purpose of discussing business matters. .~.. ~ --.... _. ......-- '- = ~ '" W .::: .... '.' ,,; -.o:t :.= ., :.; rr..:e ""'" \ . . _.,?~() ,"'... ",,'./~-::.;:' 1~ ....r.:;.;,.. 'I' .., ~.A- ~~ q~ ~.~ 91 0-.,,-,- a. ~ I~ ' " J\.}L 21 \g~'3dr- Suzette M. Steele, . IN THE COURT OF COMMON PLEAS OF . Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA . v. . 95-'~'f1.? CIVIL TERM . . NO. . Charles M. Launse, . . Defendant . PROTECTION FROM ABUSE . TEMP~Y PROTECTION ORDER AND NOW, this J l/ day of July, 1995, upon presentation and consideration of the within Petition, and upon finding that the plaintiff, Suzette M. Steele, now residing at 708 Allen Road, Carlisle, CUmberland County, Pennsylvania, is in immediate and present danger of abuse from the defendant, Charles M. Launse, the following Temporary Order is entered. The defendant, Charles M. Launse, (SSN: 198-50-4278) (D.O.B.: 08/02/63) now residing at a location which is unknown to the plaintiff, is hereby enjoined from physically abusing the plaintiff, Suzette M. Steele, and from placing her in fear of abuse. The defendant is excluded from the plaintiff's residence located at 708 Allen Road, Carlisle, CUmberland County, Pennsylvania, a residence which is leased solely by the plaintiff and which the defendant has voluntarily left. 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, except for the limited pUrpose of discussing business matters. 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. 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 tOI i) arrest under 23 Pa. C.B. 5&113; ii) a private oriminal complaint under 23 Pa. C.B. 5&113.1; iii) a charge of indireot oriminal oont_pt under 23 Pa. C.B. 5&114, punishable by imprisoDlllent up to siz months and a fine of $100.00-$1,000.00; and iv) civil oont_pt under 23 Pa. C.B. 5&114.1. Resumption of co-residenoe 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 its original expiration date if the Court fi~ds 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 not~or hearing. A hearing shall be held on this matter on the 31 day of , 1995, at ~ ~:{S-t7.m., in Courtroom No. ~cumberland County courthouse, carlisle, Pennsylvania. The plaintitt may proceed without pre-payment ot tees pendinq a turther order atter the hearinq. The CUmberland county Sheritt's Department shall attempt to make service at the plaintitt's request and without pre-payment ot tees, but service may be accomplished under any applicable rule of civil Procedure. This Order shall be docketed in the office of the Prothonotary and forwarded to the Sheriff for service. The Prothonotary shall not send a copy of this Order to the defendant by mail. The Pennsylvania State police shall be provided with a certified copy of this Order by the plaintiff's attorney. This Order shall be enforced by any law enforcement aqency where a violation occurs 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 court that issued the order. When that court is unavailable, the defendant shall be taken before the appropriate district justice. (23 P.S. S 6113). By the Court, TRUE COPY FROM RECORD /.IC/J //~ / ~ cL InTesttmonywhsreol,1 here unto set my hand , 4 ' fIV.-J. ~d"~ ~ and th seal 01 sa t Carlisle. Pa, ':I Thl {... d Y I 19 'i J / I , , cx1-/~ 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 fall 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 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 PBY 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 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 reasonable accommodations available to disabled Individuals hBvlng business before the court, please contact our office, All arrengements must be made at least 72 hours prior to any hearing or business before the court, PETITION POR PROTECTION ORDER Suzette M. steele, : IN THE COURT OF COMMON PLEAS OF plaintiff : . CUMBERLAND COUNTY, PENNSYLVANIA . v. . NO. 95- CIVIL TERM . Charles M. Launse, Defendant . PROTECTION FROM ABUSE . RELIO mrDn THE PROTECTION nOH ABUSE ACT, 23 P.S. S '101 .t ..q. A. ABUSE 1. The plaintiff, Suzette M. Steele, is an adult individual residing at 70S Allen Road, Carlisle, cumberland county, Pennsylvania 17013. 2. The defendant, Charles M. Launse, (SSN: 19S-50-427B) (D.O.B.: OS/02/63), is an adult individual. The plaintiff is unaware of the defendant's address, but believes he is living in either cumberland or Dauphin County. 3. The defendant is the husband of the plaintiff. 4. Since approximately June, 1995, the defendant has attempted to cause and has intentionally, knowingly, or recklessly caused bodily injury to the plaintiff, has placed the plaintiff in reasonable fear of imminent serious bodily injury, and has knowingly engaged in a course of conduct or repeatedly committed acts toward the plaintiff under circumstances which have placed the plaintiff in reasonable fear of bodily injury. This has included, but is not limited to, the following specific instances of abuse: a) On or about July 14, 1995, the defendant became angry with the plaintiff, who is approximately five months pregnant, and he grabbed a minibike which the plaintiff was holding, violently shaking it back and forth, causing the ~laintiff to slam against the inside of the door frame. The plaintiff called 911 and the state police responded. As a result of the defendant's abuse, the plaintiff suffered bruising on her arms, legs and a laceration on her thumb. b) On or about June 23, 1995, the defendant became angry with the plaintiff and attempted to grab the car keys out of the plaintiff's hand. The key ring was stuck on the plaintiff's finger and she could not let go, but the defendant kept pulling the keys. The plaintiff begged the defendant to stop because he was hurting her, but the defendant pulled harder. When the plaintiff positioned herself behind an electrical unit located on the front lawn in an attempt to give herself more leverage to remove her finger from the key ring, the defendant pulled the plaintiff over the electrical unit and dragged her along the ground. The plaintiff tried to turn her body away from the defendant to protect her unborn child. The defendant dragged the plaintiff approximately three yards, and kicked her in the back of the head. As a result of the defendant's abuse, the plaintiff suffered lacerations, bruises, and swelling about her legs, hands and head. 5. The plaintiff believes and therefore avers that she is in immediate and present danger of abuse from the defe.~dant should she remain in the home without the defendant's exclusion and that she is in need of protection from such abuse. 6. The plaintiff desires that the defendant be prohibited from having any direct or indirect contact with the plaintiff including, but not limited to, telephone and written communications, except to discuss business matters. 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 restrained from entering her place of employment. 9. 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. B. BXCLUSIVE POSSESSION 10. The house from which the plaintiff is asking the Court to exclude the defendant is rented in the name of Suzette M. Steele and the defendant has vOluntarily left that residence. 11. The plaintiff currently has no place to stay with her child except the marital home, and the defendant has family and friends in the area with whom he can stay. , . 12. The plaintiff desires possession of the house so as to give the greatest degree of continuity to the life of her child and allow him to continue his social activities. C. SUPPORT 13. The defendant has a duty to support the plaintiff. 14. The plaintiff is in need of financial support from the defendant including, but not limited to: the rent payment on the residence at 708 Allen Road, Carlisle, Cumberland County, Pennsylvania. 15. The defendant is self-employed and has a weekly salary of approximately $500.00 16. The plaintiff currently has no income. 17. The plaintiff petitioned for support on or about July 17, 1995. D. ATTORNEY PEES 18. 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. S 6101 ~ ~., 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 and from placing her in fear of abuse; . I , . 2. Orderinq the defendant to refrain from havinq any direct or indirect contact with the plaintiff includinq, but not limited to, telephone and written communications, except to discuss business matters; 3. Orderinq the defendant to refrain from harassinq and stalkinq the plaintiff and from harassinq the plaintiff's relatives; 4. Prohibitinq the defendant from enterinq the plaintiff's place of employment; 5. Prohibitinq the defendant from removinq, damaqinq, destroyinq or se11inq property jointly owned by the parties or owned solely by the plaintiff; 6. Grantinq possession of the house located at 708 Allen Road, Carlisle, CUmberland County, Pennsylvania, to the plaintiff to the exclusion of the defendant pendinq a final order in this matter; 7. Orderinq the defendant to stay away from any residence the plaintiff may in the future establish for herself; B. Schedule a hearinq in accordance with the provisions of the II Protection from Abuse Act," and, after such hearinq, enter an order to be in effect for a period of one year: ~~- 1. ordering the defendant to refrain from abusing the plaintiff and from placing her in fear of abuse; 2. Ordering the defendant to refrain from having any direct or indirect contact with the plaintiff including, but not limited to, telephone and written communications, except to discuss business matters; 3. Ordering the defendant to refrain from harassing and stalking the plaintiff and from harassing the plaintiff's relatives; 4. Prohibiting the defendant from entering the plaintiff's place of employment; 5. Prohibiting the defendant from removing, damaging, destroying or selling property jointly owned by the parties or owned solely by the plaintiff; 6. Granting possession of the house located at 708 Allen Road, Carlisle, Cumberland County, Pennsylvania, to the plaintiff to the exclusion of the defendant pending a final order in this matter; 7. Ordering the defendant to stay away from any residence the plaintiff may in the future establish for herself; .. 8. Grantinq SUpport to the plaintiff in an appropriate amount accordinq to the support quidelines payable to the plaintiff in the form of a check or money order, mailed to her residence, and directinq the defendant t ,.. Il,:!ke or continue to make rent payments on the residence of the plaintiff. 9. Orderinq the defendant to pay reasonable attorney fees to Leqal Services, Inc. The plaintiff further asks that this Petition be filed and served without payment of fees and costs by the plaintiff, pendinq a further order at the hearinq, and that a certified copy of this Petition and Order be delivered to the Pennsylvania state Police. The plaintiff prays for such other relief as may be just and proper. Respectfully submitted, Jt'-~~ oan Carey . Attorney for Plaintiff Supervisinq Attorney LEGAL SERVICES, INC. 8 Irvine Row carlisle, PA 17013 (717) 243-940 ,(.. ~ Marie Certified Leqal LEGAL SERVICES, , The above-named plaintiff, Suzette H. Steele, 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. 54904 relating to unsworn falsification to authorities. Date: 1-7Jn~~ ~)J~c~ uzette H. Steele, Plaintiff C'"r: JUL., i \ " :,\ i:t .,,) ~~?'~~~~IJ.':,iR"~/i~~~:hi: . '~'!';;I~~':;':',";:0':;;'r::.,', .' Pl!l\l'*Y!.VANl''''101J ~" :;,;,.~, ,.i:\~~::ift:(7.17J 204MOO-;~i .,\;';:,:;,;~'?:~ -'^ ~')::_;:,-\€6>'t ....','..,l!Ii'1717124<<l:1e"..: ': "'>.,',c,Y, .J~:;.%i~ ""r:~1;,,~~,," r' - . . '..--'-. Suzette M. Steele, Plaintiff IN THE COURT OF COMMON PLEAS OF v. CUMBERLAND COUNTY, PENNSYLVANIA NO. 95-3898 CIVIL TERM PROTECTION FROM ABUSE Charles M. Launse, Defendant AND NOW, this TEMPORARY PROTECTION ORDER :1 '-\ tt, day of July, 1995, upon presentation and consideration of the within Petition, and upon finding that the plaintiff, Suzette M. Steele, now residing at 708 Allen Road, carlisle, Cumberland county, Pennsylvania, is in immediate and present danger of abuse from the defendant, Charles M. Launse, the following Temporary Order is entered. The defendant, Charles M. Launse, (SSN: 198-50-4278) (D.O.B.: 08/02/63) now residing at a location which is unknown to the plaintiff, is hereby enjoined from physically abusing the plaintiff, Suzette M. steele, and from placing her in fear of abuse. The defendant is excluded from the plaintiff's residence located at 708 Allen Road, carlisle, Cumberland County, Pennsylvania, a residence which is leased solely by the plaintiff and which the defendant has voluntarily left. 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, except for the limited purpose of discussing business matters, 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. 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) arr.st under 23 pa. C.S. 56113; ii) a private criminal complaint under 23 Pa. C.S. 56113.1; 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-$1,000.00; and iv) civil contempt under 23 pa. C.S. 56114.1. 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 its original expiration date 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 ,"IJt day of , 1995, at ~ y,q~~,m., in Courtroom No. _~~ cumberland county courthouse, carlisle, 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, but service may be accomplished under any applicable rule of civil Procedure. This Order shall be docketed in the office of the Prothonotary and forwarded to the Sheriff for service. The Prothonotary shall not send a copy of this Order to the defendant by mail. The Pennsylvania State Police shall be provided with a certified copy 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 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 court that issued the order. When that court is unavailable, the defendant shall be taken before the appropriate district justice. (23 P,S, S 6113). By the court, L. I T" ?J( 0' i /' \ " 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 fall 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 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 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 reasonable accommodations available to disabled Individuals having business before the court, please contact our office, All arrangements must be made at least 72 hours prior to any hearing or business before the court, Suzette M. steele, IN THE COURT OF COMMON PLEAS OF plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 95- CIVIL TERM Charles M. Launse, Defendant PROTECTION FROM ABUSE PBTITION FOR PROTBCTION ORDBR RBLIBF UNDBR THB PROTBCTION PROM ABUSB ACT, 23 P.S. 5 6101 et .eq. A. ABUSB 1. The plaintiff, Suzette M. Steele, is an adult individual residing at 70B Allen Road, Carlisle, Cumberland county, pennsylvania 17013, 2. The defundant, Charles M. Launse, (SSN: 19B-50-427B) (D.O.B.: OB/02/63), is an adult individual. The plaintiff is unaware of the defendant's address, but believes he is living in either cumberland or Dauphin county, 3. The defendant is the husband of the plaintiff. 4. Since approximatelY June, 1995, the defendant has attempted to cause and has intentionally, knowingly, or recklessly caused bodily injury to the plaintiff, has placed the plaintiff in reasonable fear of imminent serious bodily injury, and has knowingly engaged in a course of conduct or repeatedly committed acts toward the plaintiff under circumstances which have placed the plaintiff in reasonable fear of bodily injury, This has included, but is not limited to, the following specific instances of abuse: a) On or about July 14, 1995, the defendant became angry with the plaintiff, who is approximately five months pregnant, and he grabbed a minibike which the plaintiff was holding, violently shaking it back and forth, causing the plaintiff to slam against the inside of the door frame. The plaintiff called 911 and the state Police responded, As a result of the defendant's abuse, the plaintiff suffered bruising on her arms, legs and a laceration on her thumb. b) On or about June 23, 1995, the defendant became angry with the plaintiff and attempted to grab the car keys out of the plaintiff's hand. The key ring was stuck on the plaintiff's finger and she could not let go, but the defendant kept pulling the keys. The plaintiff begged the defendant to stop because he was hurting her, but the defendant pulled harder. When the plaintiff positioned herself behind an electrical unit located on the front lawn in an attempt to give herself more leverage to remove her finger from the key ring, the defendant pulled the plaintiff over the electrical unit and dragged her along the ground, The plaintiff tried to turn her body away from the defendant to protect her unborn child, The defendant dragged the plaintiff approximately three yards, and kicked her in the back of the head, As a result of the defendant's abuse, the plaintiff suffered lacerations, bruises, and swelling about her legs, hands and head, 5. The plaintiff believes and therefore avers that she is in immediate and present danger of abuse from the defendant should she remain in the home without the defendant's exclusion and that she is in need of protection from such abuse. 6. The plaintiff desires that the defendant be prohibited from having any direct or indirect contact with the plaintiff inclUding, but not limited to, telephone and written communications, except to discuss business matters. 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 restrained from entering her place of employment. 9. 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. B. EXCLUSIVE POSSESSION 10. The house from which the plaintiff is aSking the Court to exclude the defendant is rented in the name of Suzette M. Steele and the defendant has VOluntarily left that residence. 11. The plaintiff currently has no place to stay with her child except the marital home, and the defendant has family and friends in the area with whom he can stay, 12. The plaintiff desires possession of the house so as to give the greatest degree of continuity to the life of her child and allow him to continue his social activities, c. SUPPORT 13. The defendant has a duty to support the plaintiff. 14. The plaintiff is in need of financial support from the defendant including, but not limited to: the rent payment on the residence at 708 Allen Road, Carlisle, Cumberland County, Pennsylvania. 15, The defendant is self-employed and has a weekly salary of approximately $500,00 16. The plaintiff currently has no income. 17. The plaintiff petitioned for support on or about JUly 17, 1995. ~...... D. ATTORNEY PEES 18. 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. S 6101 et sea., 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 and from placing her in fear of abuse; 2. Ordering the defendant to refrain from having any direct or indirect contact with the plaintiff including, but not limited to, telephone and written communications, except to discuss business matters; 3. Ordering the defendant to refrain from harassing and stalking the plaintiff and from harassing the plaintiff's relatives; 4. Prohibiting the defendant from entering the plaintiff's place of employment; 5. prohibiting the defendant from removing, damaging, destroying or selling property jointly owned by the parties or owned solely by the plaintiff; 6. Granting possession of the house located at 708 Allen Road, Carlisle, Cumberland county, Pennsylvania, to the plaintiff to the exclusion of the defendant pending a final order in this matter; 7. ordering the defendant to stay away from any residence the plaintiff may in the future establish for herself; B. Schedule a hearing in accordance with the provisions of the "Protection from Abuse Act," and, after such hearing, enter an order to be in effect for a period of one year: 1. ordering the defendant to refrain from abusing the plaintiff and from placing her in fear of abuse; 2. Ordering the defendant to refrain from having any direct or indirect contact with the plaintiff including, but not limited to, telephone and written communications, except to discuss business matters; 3. Ordering the defendant to refrain from harassing and stalking the plaintiff and from harassing the plaintiff's relatives; 4. Prohibiting the defendant from entering the plaintiff's place of employment; 5. Prohibiting the defendant from removing, damaging, destroying or selling property jointly owned by the parties or owned solely by the plaintiff; 6. Granting possession of the house located at 708 Allen Road, Carlisle, Cumberland County, Pennsylvania, to the plaintiff to the exclusion of the defendant pending a final order in this matter; 7. Ordering the defendant to stay away from any residence the plaintiff may in the future establish for herself; 8. Granting support to the plaintiff in an appropriate amount according to the support guidelines payable to the plaintiff in the form of a check or money order, mailed to her residence, and directing the defendant to make or continue to make rent payments on the residence of the plaintiff. 9. Ordering the defendant to pay reasonable attorney fees to Legal Services, Inc. The plaintiff further asks that this Petition be filed and served without payment of fees and costs by the plaintiff, pending a further order at the hearing, and that a certified copy of this Petition and Order be delivered to the Pennsylvania State Police. The plaintiff prays for such other relief as may be just and proper. Respectfully submitted, -f<.. (1 ,-,/- tit-Ie; _(/ oan Carey Attorney for Plaintiff Supervising Attorney LEGAL SERVICES, INC. 8 Irvine Row Carlisle, PA 17013 (717) 243-940 /' Date: 'l-7[) r7 \ ~KlC.J,-- /C( ~)... '- 5uzette M. steele, Plaintiff The above-named plaintiff, Suzette M. steele, 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. 54904 relating to unsworn falsification to authorities. '- t::: ,- r-..) ~ c..~ .... .1" C., -...... '"' -~ ~" ~ u::. 'tori ~ ','"-. Ay the Court, SUZETTE M, STEEI.E. Plnintiff IN TilE I'OURT OF COMMON PI.EAS OF CIJMIIr,Rl.t\NIJ ('OUNTY, PENNSYLVAN I A v. NO. 95-3H9R CIVIl. TERM CIIARLES M, J.AUNSE, Ilefendnnt PRCYrECTION FROM ABUSE ()RIlI(R AIR aWrJ NlIANC"; AND NOW, this '1tl dny of September, 1995, upon consideration of the attached Mot ion for Cont inullnce, tbe mlltter rescheduled for hellring on September 6, 1995, Ilt 3:00 p.m., by this Court's Order of July 31, 1995, is hereby continued genernlly. This Order is entered without prejudice to either party to request n hellring. The Tempornry Protection Order shill I remnin in effect for Il period of one yenr 01' until modified 01' terminated hy the courtllfler notice or hearing. Cert i fied copies of this Order for Cont inunnce wi II he provided to the Pennsylvanin Stnte Pol ice nnd the I'llI'I isle Pol ice Depllrtment by the plnintiff's nttorney. ,J, C;.~ ;:-",' -.c' Phi I ip c. Arigllnt i JOlln Cllrey .fnne Muller-Peterson J.ECoAl. SF.RVIC~;S, INC. Attorneys for Plaint iff .r;. .c ..,~ :::=: .~ Rnlph II. Pinsky PINSKY /I< FOSTER Attorney for Ile fendllnt C"'~J~'-"":' ,......."..l...( ? /~ I';!)' ..1,," . SUZITI'E M. STEEI.E, Plnintiff I N TIlE COURT OF COMMON PI.EAS OF CllMBERI.ANIl COUNTY, PENNSYLVANIA v. NO. 95-3898 CIVIL TERM CHARLES M. LAUNSE, Defendllnt PROTECTION FROM ABUSE I<<YI'ION ~l)R CONT I NUANCE The plnintiff moves the Court for nn Order continuing generally the hellring in the above-captioned cllse on the grounds that: t. By ngreement of the pnrties, the plaintiff's counsel filed II motion for continunnce IInd an Order WIIS entered on July 31,1995, reschedUling the henring to September 6, 1995, lit 3:00 p.m. 2. The defendnnt retnined Rnlph B. Pinsky of PINS", '" FOSTER to represcnt him in the mlltter. 3. The defendnnt's counsel requested II continullnce in thi:; mlltter. 4. The plaintiff does not oppose u continullnce upon the condition thut the Temporary Protection Ordcr remllin in effect for u period of one year or unt i I modi fied or terminuted by the court lifter not ice 01' hearing. 5. Certified copies of the Order for ContinulIllce will be delivered to the Penllsylvanin Stute Pol ice and the Cllrl isle Pol ice Depllrtment by the attorney for the plllint iff. WHEREFORE, thc plaint iff requests thllt the Court gl'llnt this Mot ion and continue this mllttcr genel'lllly, lIIul thllt the Temlxlrnry Protection Order remain in effect unt i I furt her Order of Court, Respect fu Ily submi lted, , ) . l't..'''}'t../ C!:lt. 'tJ!..~ J un Cllrey Attorney for Plainti I.ECoAJ. SF.RV I CF4'> . INC. V> no "'" -I ~ . M, .r:' '" ~~ .= .., ~)0 ,"'" ......