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Home My WebLink About95-03943 ~ 4 ., J ~ I I I I ~ i ! I I I ~ i I i Q-. P) specific instnnces of nbu!le: a. On 01' Ilboul. ,Juiy 17, 1995, Ilt. IIpproximnt.e1y 4:30 a.m., t.he defendnnt. Cllme t.o t.he p1alnt.lff'lI refddonco while she WIIS sleeping, pounded on t.ho front. door wit.h his fist. Ilnd yelled vlie names at. her, Ilnd pounded on the t.raller while wlllkin~ around It. t.o the plaintiff's bedroom window, Ilnd smashed hla fiRt through t.he window yelling at. the plaintiff demandln~ that. she open t.he door. The defendant returned t.o the front. door continuing t.o pound on t.he side of t.he trlliler. The defendant. pounded on the front. door wit.h his fist., smashed the front door panel, and pulled t.he acreen door loose causln~ the plaintiff t.o fear for her life. A neighbor came outside and t.he defendant left. Fearing for her Bafet.y, t.he plaint.iff called the police and criminal oharges were filed against the defendant. b. In or about March 1995, the defendant came to the plaintiff's residence uninvited and llnocked on the door. When t.he plnintiff opened the door nnd saw who it was, she tried to ahut the door, but the defendant forced his wny into her home and yelled at the plaint.iff. The defendllnt. ~rubbed the plaintiff in the crotch nren nnd yelled vile names at her, The defendant I.hl'n ~rllhbed t.he plnint.l ff'a armB and repelltedly kick t.he plaintiff In the legB causing 2 bruises. The pllllnt.lff stl'U!!!lled free of t.he defendllnt.'fl !!1'lp 111111 st.III't.ed t.owllrds t.he front. door, but t.he defendllnt. Ilrllbbed her by t.he hall', pulled her Into the kit.chen, IInd repelltedly kicked her. When the plnlntl ff st.ru!!!!led fl'ee ugllln IInd rlln t.ownrds IInother room, the defendant. !lrabhed hor, throw her onto a sofa, and repeatedly punched her In the chest cBuslng bruises. c. Since Au!lust 1994, when the plaintiff ended the relationship, the defendant hus repeatedly called her at. home nnd at. work threat.ening to hnrm her cuusing her to fellr for her SlIfety. On one occlIsion, the defendllnt slapped the plllintlff twice in tho fllce IInd forcefully pushed her cllusln!! her to filii to the floor. 5. The plllintiff believes and therefore avers that she is in Immediate and present dBn!ler of ubuse from the defendant and that she is I n need of prot.ection from such Bbuse. 6. The plaintiff desires t.hut. t.he defendant be prohiblt.ed from having any direct or Indirect contBct with the plaintiff including, but not. Ilmit.ed t.o, telephone and writ.t.en communicBtlons 7. The plaintiff desires that the defendant. be enjoined from harassing and stalking the plaintiff, Bnd from harassing the pllllntlff's relatives. R. Tho pJllintiff desires t.hat. t.ho defendllnt be restrained 3 '7. from enterlnH 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. n. F.XCI.llSlVE POSSESSION 10. The mobile homn which tho plaintiff is asking the Court to order the defendant to stay away from Is owned In the name of the pia Int.1 fl'. 11. The defendant has is own residence located at 122 E, Garfield Street, Shippensburg, Pennsylvania. D, I,OSSES/ATTORNEY FEES 12. The plaintiff has suffered losses as a result of the abuso by the defendant. The losses are listed on Exhibit A attached. 13. The plaintiff asks that the defendant be ordered to pay reasonable attorney fees to Legal Services, Inc. WHERF.FORF., pursuant to tho provisions of the "Protection from Abuse Act" of October 7, 1976, 23 P.S. ~ 6101 et seq., as amended, the plaintiff prays this Honorable Court to grant t.he following relief: A. Grant a Temporary Order pursuant to the "Protection from Abuse Act:" 1. Orderlns the defendant to refrain from abllfllng the plaintiff or placing her in feat' of abuse. ., 2. Ordering the defendant to refrain from having nnr direct or indirect contact with the plaintiff 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 entering the plaintiff's piace of employment. 5, Prohibiting the defendant from removing, damaging, destroring or selling propertr jointly owned by the parties or owned solelr br the plaintiff. 6, Ordering the defendant to star awar from the plaintiff's residence located at 8 Ritner Gardens, Shippensburg, Cumberland County, Pennsylvania. 7. Ordering the defendant to star awar from any residence the plaintiff mar in the future establish for herself. B. Schedule a hearing in accordance with the provisions of the "Protection from Abuse Act," nnd, 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 plainLiff or placing her in fear of abuse. 5 2, Ordering the defendant to refrain from having any direct or indirect contact with the plaintiff including, but not limited to, telephone and written communicnt.lonH. 3. Ordering the defendant to refrnin from harassing nnd stalking the plaintiff and from harnnsing the plalntlff'H relatives. 4. ProhibltinK the defendant from entering the plalntlff'H plnce of employment. 5. Prohibiting the defendant from removing, damaging, destl'oylng or selling property JoinUy owned by the parties or owned solely by the plnlnt.lff. 6. Ordering the defendant to stay away from the plaintiff's residence located at 8 Ritner Gardens, ShlppensburK, Cumberland County, Pennsylvania. 7. Ordering the defendant to stay away from any residence the plaintiff may In the future establish for herHelf. 8. Ordering the defendant to reimburse the plalntlff'H out-of-pocket )osses suffered as a resu) t of the ubuse including but not limited to the )OHROS linted on the attached Rheet marked Exhibit A. 9. Ordering the defendant to puy reasonable 6 pamala J. Wilson, plaintiff : IN THE COURT OF COMMON PLEAS OF . . CUMBERLAND COUNTY, PENNSYLVANIA NO. 95-3943 CIVIL TERM v. Mike A. Crouse, Defendant PROTECTION FROM ABUSE ~~PROTZCTIOM ORDZR AND NOW, this ~ day of August, 1995, upon consideration of the Consent Agreement of the parties, the following Order is entered: 1. The defendant, Mike A. Crouse, ss:(unknown) and DOB: 4/8/63, is enjoined from physically abusing the plaintiff, pamala J. Wilson, and 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 written communications. 3. The defendant is ordered to refrain from harassing and stalking the plaintiff and from harassing the plaintiff's relatives. 4. The defendant is prohibited from entering the plaintiff's place of employment. 5. The defendant is prohibited from removing, damaging, destroying or selling any property owned by the plaintiff or jointly owned by the parties. 6. The defendant is ordered to stay away fro~ the plaintiff's residence located at 8 Ritner Gardens, Shippensburg, ct. \1' ...' ..- ".,. :J'~ I i l ~ J." Cumberland county, Pennsylvania, 17257. 7. The defendant is ordered to stay away from any residence the plaintiff may in the future establish for herself. B. The defendant is ordered to pay $20.00 per week beginning August 7, 1995, until he has paid a total of $400.00 to the plaintiff for the losses described in Exhibit A. An award under this chapter shall not constitute a bar to litigation for civil damages for injuries sustained from the acts of abuse giving rise to the award or a finding of contempt under this chapter. 9. This Order shall remain in effect 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. 10. This order may subject the defendant to: i) arrest 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. 11. The pennsylvania state police Department shall be provided with certified copies of this Order by the plaintiff'. attorney and may enforce this Order by arrest for indirect pamala J. Wilson, Plaintiff v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 95-3943 CIVIL TERM Mike A. crouse, Defendant PROTECTION FROM ABUSE CONSINT AORIIHINT ~ This Agreement is entered on this ~~ day of August, 1995, by the plaintiff, pamala J. Wilson, and the defendant, Mike A. Crouse. The plaintiff is represented by Joan Carey of LEGAL SERVICES, INC.; the defendant is unrepresented but is aware of his right to have an attorney. The parties agree that the following may be entered as an Order of Court. 1. The defendant, Mike A. Crouse, agrees to refrain from abusing the plaintiff, Pamala J. wilson, or placing her in fear of abuse. 2. The defendant agrees not to have any direct or indirect contact with the plaintiff including, but not limited to, telephone and written communications. 3. The defendant agrees not to harass and stalk the plaintiff and harass the plaintiff's relatives. 4. The defendant agrees not to enter the plaintiff's plac. of employment. 5. The defendant agrees not to remove, damage, d..troy, or sell any property owned by the plaintiff or jointly owned by the parties. 6. The defendant agrees to stay away from the plaintiff's residence located at 8 Ritner Gardens, Shippensburg, CUmberland county, Pennsylvania, 17257. 7. The defendant agrees to stay away from any residence the plaintiff may in the future establish for herself. 8. The defendant agrees to pay $20.00 per week beginning August 7, 1995, until he has paid a total of $400.00 to the plaintiff for the losses described in Exhibit A. 9. The defendant, although entering into this Agreement, does not admit the allegations made in the Petition. 10. The defendant understands that the protection Order entered in this matter shall be in effect for a period of one year or until modified or terminated by the Court after notice or hearing and, can be extended beyond the 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. 11. 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 entered to reflect the above terms. 1~<JJ,,- ~. ~~~,tV Pamala J.'wilson, plaintiff lo" ,J@Hr (~( ( oan carey ., Attorney for Pl& ntiff LBGAL SERVICES, INC. 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 a Gf.Hw2 Mike Defendant ,J ::::l r. ~ l ",. c: .., .<::.. IlO N . _. .... l.;' "- .... I) ,~., - " ..., &, .... "-- 1': = ~ . ":1- -. ~.' LC <J1