HomeMy WebLinkAbout95-05144
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CARA J. ROGERS-BRADHAM"
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V.
95-5144 CIVIL TERM
PARRISH T. BRADHAM,
Defendant
CHARGE: INDIRECT CRIMINAL CONTEMPT
ORDER OF COURT
AND NOW, thi~ day of January, 1996, this Court
certifies that the attached complaint has been properly completed
and verified, and there is probable cause for the issuance of
process, In consideration of the attached Commonwealth's
petition, the defendant, PARRISH T, BRADHAM, is directed to
appear for trial on the charge of Indirect Criminal Contempt
before the Court on the ____ day of , 1996 at
o'clock ___ .m. in Courtroom # __ of the cumberland county
Courthouse, Carlisle, Pennsylvania,
The defendant has a right to be represented by an attorney,
If the defendant cannot afford an attorney, upon request one will
be assigned to represent the defendant. If the defendant wishes
assignment of counsel, contact should be made prior to trial with
the Cumberland County Public Defender's Office at 717-240-6285,
Further, if the defendant fails to appear, an arrest warrant will
be issued,
The Sheriff of Cumberland County is directed to serve this
Order and Petition upon the defendant, The assessment of costs
to be determined by the Trial Judge subsequent to trial.
By the Court,
J. Wesley Oler, Jr.
J.
Thomas A. Placey, Esquire
Senior Assistant District Attorney
PARRISH T. BRADHAM
CARA J. ROGERS-BRADHAM,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V,
95-5144 CIVIL TERM
PARRISH T, BRADHAM,
Defendant
CHARGE: INDIRECT CRIMINAL CONTEMPT
ORDER OF COURT
AND NOW, this day of January, 1996, this Court
certifies that the attached complaint has been properly completed
and verified, and there is probable cause for the issuance of
process, In consideration of the attached Commonwealth's
Petition, a WARRANT IS ISSUED FOR THE ARREST of the Defendant,
PARRISH T, BRADHAM.
If the defendant is found during normal Courthouse hours,
the defendant is to be brought immediately before the Court, If
not found during Courthouse hours, the defendant is to be taken
to the on-call District Justice and bail set pursuant to the
Rules of criminal procedure. Furthermore, after appearing before
the District Justice the defendant is advised to appear before
the Court Administrator at the open of the next business day,
Defendant has a right to be represented by an attorney. If
the defendant cannot afford an attorney, upon request one will be
assigned to represent the defendant. The assessment of costs to
be determined by the Trial Judge subsequent to trial,
By the Court,
J. Wesley Oler, Jr.
J.
Thomas A. Placey
senior Assistant District Attorney
PARRISH T. BRADHAM
CARA J. ROGERS-BRADHAM"
plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V,
95-5144 CIVIL TERM
PARRISH T, BRADHAM,
Defendant
CHARGE: INDIRECT CRIMINAL CONTEMPT
COMMONWEALTH'S PETITION FOR A HEARING ON CHARGES
OF INDIRECT CRIMINAL CONTEMPT
Thomas A, Placey, Senior Assistant District Attorney of
Cumberland county, pennsylvania brings the following petition for
a hearing on charges of Indirect criminal contempt:
1. A protection from Abuse Order was issued by the Court.
A true and correct copy of the Order is attached.
2. The defendant's violation of this Order is averred in
the attached private criminal complaint,
3. The victim requests the filing of an Indirect Criminal
Contempt charge upon information received.
4, The District Attorney's Office approves the filing of
this private criminal complaint.
S, The commonwealth is requesting a tt'ial on the charges
of Indirect Criminal contempt pursuant to 23 Pa.C,S.A. S61l3,
6, The plaintiff and the defendant may seek modification
of the Order based on the filing of this petition as the Court
deems appropriate following the trial in addition to any other
sentence. 23 pa.C.S.A. S6117.
WHEREFORE, the commonwealth requests the defendant be
commanded to appear before the Court on the charge of Indirect
criminal contempt,
Respectfully submitted,
)
/
, \
ThQmas,A. placey
Senior Assistant District Attorney
I
J'
Cara J. Rogers-Bradham,
Plaintiff
IN TilE COURT OF COMMON PLEAS OF
v.
CUMBERLAND COUNTY, PENNSYLVANIA
NO, 95-5144 CIVIL TERM
PROTECTION FROM ABUSE
parrish T. Bradham,
Defendant
PROTECTION ORDER
AND NOW, this ~daY of october, 1995, upon consideration
of tho consent Agreement of the parties, the following Order is
entered:
1, The defendant, PARRISH T. BRADHAM, ~S:136-62-1874 and
00B:9/24/62, is enjoined from physically abusing the plaintiff,
CARA J. ROGERS-BRADHAM, and from placing her in fear of abuse,
2. The defendant is ordered to refrain from harassing and
stalking the plaintiff and from harassing the plaintiff's
relatives.
), The defendant is prohibited from entering ~he
plaintiff's school.
4, The defendant is prohibited from removing, damaging,
destroying or selling any property owned by the plaintiff or
jointly owned by the parties.
5. The defendant is ordered to enter and complete a drug
and alcohol counseling program and attend relationship
counseling,
6, The court costs and fees are waived.
'I. 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 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,
8, This Order may subject the defendant to: i) arrest
under 23 Pa.C,S. S6113; ii) a private criminal complaint under 23
Pa,C.S. S6113,1; iii) a charge of indirect criminal contempt
under 23 Pa,C.S. S6114, 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. S6114,1, Resumption of co-residence on the part
of the plaintiff and defendant shall not nullify the provisions
of the court order.
9, The Lower Allen Township police Department shall be
provided with a certified copy 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 court that issued the
order. When that court is unavailable, the defendant shall be
taken before the appropriate district justice. (23 Pa.C,S. S
611 3) .
TRUE COpy FROM RECORD
In Tlntimony whereof, I here unto sel my hand
and the seal of said Court al Carlisle, Pa.
I 'J U f (~ 19 'i'/~
This...." day 0, ...., ,iI;r",,,,,,, .. ~.
, "...t'l
......,....,"";,,~.~ i" I'~~J',;' !:p~~i'~::J:~\I_'
'''-'f~J'
Cara J, Rogers-Bradham,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 95-5144 CIVIL TERM
v,
Parrish T. Bradham,
Defendant
PROTECTION FROM ABUSE
CONSENT AGREEMENT
This Agreement is entered on this \l~ day of October,
1995, by the plaintiff, CARA J, ROGERS-BRADHAM, and the
defendant, PARRISH T, BRADHAM, 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, Parrish T, Bradham, agrees to refrain
from abusing the plaintiff, Cara J, Rogers-Bradham, and placing
her in fear of abuse.
2, The defendant agrees not to harass and stalk the
plaintiff and harass the plaintiff's relatives,
3, The defendant agrees not to enter the plaintiff's place
of school,
4, The defendant agrees not to remove, damage, destroy, or
sell any property owned by the plaintiff or jointly owned by the
parties,
5. The defendnt agrees to entor and complete drug and
alcohol counseling and attend relationship counseling.
6. The defendant, although entering into this Agreement,
CRIMINAL COMPLAINT
(POLICE)
COMPLAINT t~UMBER
VEAR
1995
TYPE':
NUMBER
. ---------...-------------.-- ---
rom'!' OF CX11,f>llN l'U:J\.S J
DISTRICT JUSTICE
MAGISTERIAL DISTRICT NO,
(I !.I(Y1!:,l,.!L,r d
, g{JI,I,~d L(~n-rI'Y C'O{JWl' I ',(XI: a':
I TELEPHONEJ )
Cumplolml Numhv,," Oth., 1''''hC'II."U
4861.J-l
,'riCIOENTNUMElER UCfVNlDAS-l'iO, OTN
95-12-10565 2730
(lAlf rll[O.
IlEG PLATE NO
ANNUAL STICKEfl tlD
OPEf1ATOfI'S L\Cl.N'il 110
COMMONWEAL TH OF PENNSYLVANIA
Ill, f' fNOAN I VS
NAMI. r
"'Nil
I\DllIH'.SS
"r
,-Mf,;"fi Ij;'I~';'-'-II;';'; ".;,j~..~I;-I.;"t"~:'~:'I/l.;i ,,;,;, ". f",,-;,jj";.;;-,.~;,/lIII""1
pJ\RRISH 8RADHJ\M
624 Cl\MP ffi'REET
fl1lRRI SBURO, [>/\.
8IM/33
SSN 136-62-1874
09/24/62
I,
l'I\'IW>l, OFI,'](1':fl (l11,TN 11 ,!':ilJlY II fl.,..
/,\,jllll'oI,.\1'''Jllli
Cl'J'Y OF IIJIJiFlf:JIlI!/O 111111,:/11' OF \Ol.lCF.
IISA
A'" A
I)(JII
dll hen.hy !;tuh!: 'j:;.
11lL]X I nt'('lISI' tlU' uhovl' l1unwd dl'r"llllant, whu livt's Ilt llw atldrt's!i !:il't (urth ahovt' or.
[} I U\'I:USt' an IIHIt\'uhml whilSt' IHlIlIP IS unknown lu 1lH' hut whu is dl'Sl'f1ht'd as_ ,-
,
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t
,
.
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[] IllS llil'knanH' or pllpular dl'~Ii.:I\lIlICH1 is unknown (I) llW UlIll, t1Wft,rOfl'. I h"vI' dt'sl~llatt'd hllll Iwrl'in as John DOt';
With vllllnllllA tilt' I"'llallaws or till' ('1l/llIllOllW,'nllh or 1'1'llllsylvalliaat ,/'40.1.,1' 4111 :nJlI~I.~l'__
./'o'.J,.I'"",,,.II.\I,",/I,'II,"I,
HJ\RJnm~jlq"J'!L III ,_DAI}PHI1L. ('O!Jllty un ur ahtllll 3HJ,],:r;, 19;J_5. @ 1940 HRS,__
Purlil'ipanls "'t'rt' III iiI,'''' '''''''1,,/'1/, '(""'" 1'/"'. Oil'" ",,""'1 I",,., 'l'l'r,J'I'I~ """hJIII" ,,, ,/f"", .t.." ",t,J'I"
(21
The ncts committed hy tilt' "''''lIsl'd wew:0) Il'VIRECl' QUMlNI\L CX1m'EMPI'
'IHE ACl'OR I1lD VlOUm; PRC1l1:Cl'rm: moo ABUSE ORDER DA'I'FD 17. OC'IOBER 1995,
Al'D SIGNED BY 'IliB IlOmlWll.f: JUOOE J. WESLEY OLER OF' aJ!.IBER1.N-<<) ccmn'Y allIR'I',
THE ORDER NUl-1BER IS 95-5114 IN 'I'llAT TIlE oDF.FENDlINT DID FORCE CMA ROGF.RS '1'0
DRIVE /IOAmS'!' HER WII..!., '1'0 '!1IF: 2400 BLK OF N 4111 S'!', 'IllEN HT1-Bl':J\'!' HER IIFJ\D /IOAINS'!'
THE DASH OOARD. ~ -r rI ...f " ..{ T C
ON INFOR~1A'l'roN RECEIVF1J
nllllr whll'll WNt- ngainst lilt' pI'a,,,' alld diAl\Ity or the Commonw.'nlth or I'I'nnsylvanianlld contrary tu tlH' Act or Assemhly,
ur 111 vllllntiull or 2~,"""""" j'I1!-l or the Ad or..;!3-Pa...('~c:;.Ar,-61-13-SlJP- p. 0'" '9Qn
PI ,.11..11'11'1'1,,11I1
or lh.,
()rdll1alH'I' or
11',,;/111'.11 .\Id' ,fi.-;,~;';,-._-- ___,___'n
l:1) I ask thut U \\'lIrranl or arrl'st or a .;lIIHIIlOnS he issued und that the nl.t'lI~I'd til" rt!qllirt~d tu anSW(,f the ehar~es I
hnve mnde,
III I vl'riry that t1w fal'tJol !owl. forth ill tltls "ol1lpluinl l1wlrul' and l'orrt'l't tn lilt' Ill'sl or my knowlt.dj.,:t' or informuliolt
lUltll)(l!it.r. This \'l'rinl~nlil)n is m;ull' SUhJI'I'lln the IlPnaltit's of HI!I'UOn ,mOl of till' CdlTH'S Cudt' 11 H Pn. C. S.
~ ,lBO-I) rl!lntingto unsworn fnlsifkatiol1 to nuthorith's.
1.2.L) ';
____ ,I!l 7)'
C- /---:.' '/----
r-- C..-- --
. .....---
, , .. '1 'I ~ ,', " " (:" ", f' / ,j ~ '1 ,j ,"
,
,\ND NOW. 011 this <lnl<' __'~..~. ,~\ "J\Lcf:') _ 1 cl'rWy till' t:nmplllinl 1111' hl','n prtl,,,,rly t:nl11)1leted nnd
lfl'rifil'd. lind that lIwrP is prohllhh' l'II\lSI' fur t.lw issuance of pnH~pssQ__
__~f,.)-;:o...~\_ (lUl)"u' ,6 ,1)U-l...Q.Q{,V'~'H';AI.I
1\I".",/,.,::7T'"I""",1 ~''''Il
AtWe ..I' ,,~
,...."""',_.....".
pia l" t 11 1 a" d I rom h a r ass 1 n9 UIC' P 1 a '" ~ , f ' ' '; r l! I u t , ve ,; ,
ft1t:.! 1efend,\nt ,-:; enjolllecJ from ~ntl~r"'HJ th8 pl",,<,t1ff's
'31.1'<1\ 11
rf)H t1Hfendrtnt 1S enjoined flom rfJlll,Y/l'l(J. d,tITli191nl]1
dIJ~';tri'/ltlg Of ,~>"l!'rl'J ilny propHf'fy l)wqed J 11tlt 1)' by till! partlHs
o I r:l'l'HIIH1~ (') 1 e 1 y h)' t. 11 P. P 161 n t 1 f f .
A violat ion 01 this Order may subjer.l I tin defendant to: i)
arrest under 23 Pa.C.S. !l6113; i i) a privlltn criminal complaint
under 23 Pa,C.S. ~6113.1; ii i) a charge 01 indirect criminal
contempt under 23 Pa.C.S. !l611', 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. !l611'.1. Resumption of co-residencs on
ths part of the plaintiff and defendant shall not nullify the
provisions of the court ordsr.
This Order shall remain in effect unt,l modified or
termlnated by the Court after notice or hear,ng 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 plaint iff.
day ,,f
A heanng shall be held on th,s matter ,')n the
/.. ' .
SOfll-'ilmbe.., 1995, at .,',
; ,.,.t.~.'
.In, I
It' Court room rlo.,-'
Cumb.,rl'lnd County C,)urthouse, Ca'" isle, PE!I,nsyl/"n,a.
Ttll~ plrl,nt It'( may proceed wlthQut p"e-paynH~nt of fe'~s
penel,ng ,\ furt""" ",'der after tl,e hear""3,
fIll' C'"11II1,..l(/,'j County 511.., "f'~, Departrn,,,,! ",hall :dtempt to
Cara J, Roqers-A,adham,
1'1 a, nt , Ii
IN THE COURT OF CO'.IMC>N PLEAS OF
CUMBERl.AND COUrlTy, 1,"-'NNSYl.'/A'1l1\
NO. 'l5-
C II 'I. Tf-rl~1
Parrlsh '", F!'~tl1hil'n,
lIB! end ant
PROTECT ION FHOM MlUo,F
NorlCE
You 11d'/e Lpen suerj In r.':HJrt. If Y().J W1S~1 '.n dHtunrl nq':-\lll.;t tht!
claIms set forU1 111 the l"llow'"g pages, you mu';t tilh" iI\,t Ion rrr;nlptl
after thIs P"tlt,on, ':"'rJ~1 i1l1l1 Noticp. ilre salven, l,y :tppea.-rn9
persona 11 y or b, at torney ,I' the hear ;ng sciledu led l.y t he Court arHj
present ing tl:' the COUlt your defenses I)" objectIons to the c1ilHns g'jt
forth a9aln~:t you. You ilf'l] warned that if you filil to (10 sO the Cnurt
may proceed w,thout you, and a judgment may be entered against you by
the Court witho"t further notice for any money clairnorj In the Pet:1tion
or for any other claim or relief requested by t'1e plalntiff, You mdY
lose money or property or other rights important to you,
FE_ES AND COSn
If the case goes to hear ing and the judge gral1ts a Protect ion
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 taks 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
A',1ERICANS WITH DISABILITIES ACT OF 19')O
The Cou rt 0 f common Pleas o'f-Clj'mber', and'-Coli';i:'y 1 S requ Ired by 1 aw
to comply 1'/1th t'1e Amel1ca"" with DisabilIties Ad (1f 1 ",gO , Fur
infnrmatlon ahout .lcces'.11bl.1 fncilitles and reasonatJlf~ :'ccOmITlO{l.lt~"1n'.',
aVCll1abla t,) dl~;dhl~d ll1dlVldunls havln~l bUSlne!..,s bL,f,lro the ('()lJ,.t,
pluase contact nur olIIC", ,\11 arrangem""t>; must be 'Iurle at 1",,:,1, 72
hout's pI" lor to .tllY h'~d"lnl.J ,)1' business before the C(llJf-t. '(nil mll::,t
attend ttH~ ';CIH'd\,l~t1 (.l)nftl'\~IlLH 0" hear1ng.
Cara J. Rogers-Br~dham,
Pla.n' Iff
IN nil' COURT or CllMI.lOl1 Pl.EAS (IF
CUI.lBERl,ANO COUNTY, PENNSYl~~NI~
v,
~j(l. ,] r') _
C I \ (L T EfH,I
Parrish, Bradham,
[1t1fenoetl1t
PfWrrCTlON FROM ABU':'E
PET (T ION FOR PHO r FC r ION ORPER
HELIEI' UNOI'll rilE PHorrC110N FROM ABUSE
AC1, 23 Pa.C,S, 9 6101 et seq.
^ . ABUSE
1. The plaint 1ff, r.ara T, Rogers-Bradham, 15 an adult
individual res,d,ng at 221~16 L Cedar Run Drive, Camp H.ll,
Cumberland County, Pennsylvan,a ,
2. The defendant, Pa"r1 sh 1. Bradham, SSN: 136-62-1874 and
DOB: 9/24/62, is an adult ,ndividual residing at Cumberland
County Prison, Cumberland County, Pennsylvania, 17013.
3. The defendant is the plaintiff's husband,
4. Since approximately 1989, the defendant has attempted
to cause and has intentionally, know.ngly, or recklessly caused
bodily injury to the plahlt1ff, commItted spousal sexual assault,
has placed the plaintiff in reasonable fear of imminent serious
bodily injury, and has knowingly engaged in a course of conduct
or repeatedly committed a~t5 toward the plaintiff includ,ng
following the plaint 1ff wttl,out proper authorizat iOl1, under
cIrcumstances whIch ha.e placed the pl~lntiff in reasonable lear
o I bod i I y "1) u r y .
Till:, h-1S 1Ilclud~~d, nut is not 11rnlted to, thl!
lollowing sper.i I IC 1n5t ,,,'c.'s 01 "bu,~,,:
a, On 0" allolJ! 4ugu"t 21, 1 '195, the defendant came In
thf) rJl:"\lllt:tf'.-, rf~S\ tt-'t't-:' and Wt-int frorT1 her frCd\P dH-,r
to tH-P pat 1'\ d:)'ll f,' ttl'JlIt an hour n~g91rl\) tlH' t t~t
hIm In.
Aft,.r dn h -,11'
....hp-11l t he deff~ndilnt ',()fl" 1 1\( .'t'
he' to orpn t ~H' ,tIJ-lI t If 1 Ll' t.1I0 in t tH:' c1HfendcHlt
g!ilhtItJt! thr' n~:'ll"tlfj tl, II'-llh <Inns and stu(k I\~c:. t n.ll.~!
do",n he I t..1 r ');1 ~ ,
','/h.-I' tll'-: plantlff 9(lt aWi'I'j il1l1 Vi,'llt
to g.~t her tl~lt)r\qlr>g, 11':: lH8Je, tht:! dHfen;la'lt I HP':
gIn b bin 9 .-1 t t i lt~ I' 1 n. ; n I 1 f f, P u $ h e d her I P i 1)11 I! d t tH~
plalnt;ff do,.n un the Iled, tried t~) smother the
plaintiff wIth it 8,11,-1'1 ind held her by the front of
the neck 30 st,e couldn't treathe, When the plaint1ff
was able to get aHay, the defendant again pinned her
down on the floor of her closet. When the plaint,ff
managed to get out of the room and move toward the door
to leave, the defendant grabbed and squeeZed her arms.
The pla,nt,ff was able to get to her car and leave the
residence. and when she went back to her home latel,
the defendant Wil" st i 11 there and refused to leave,
The defendant demanded to have sex with the plaint i ff
and when shl! I tJ fused, hp pushed her down on her bd'-' ,)n
the hell. pul',..,lll"r sl1<'lrt, 0pen, grabbed tile
pla1flldf'S "nee". pul1.."j them apart and ,'aped h,,".
The p\C\lllt 1ft I~ a11~d tlH' Pdl1r:e.
b, On or .I)'.ut ~u'l\Jst '.1, 1995. the defendant ,,,pe;I.,j
the plaInt'!! to the 'l""'''.! ~nd slashed all of the
t 1 ,-~5 on he'- .~ iJl ,
c. DurIng AU'lust clf 1 J9~, tho" dpt"lIrJ.int threate""d
to kill the nla,"t1lf,
d. Si"Ct~ i:lpprOI(1mat..!1/ r1t;t(t!rnb':jf If 1~194, the
defendant tl'lS abu'oed tIlt' pl:t"l~\ff In ways, lncltHlln'_I,
but not l1mlted to ::J1~d)l)l'l~l. pu'-d)lf\rl, PLll11ng, gltt:1blllJ
hillr ilnti 0I3''''g thredt
e . A P P ,. OJ 1 mat f~ 1 y .2 ;) r oi,' e a ,- s a 10 I the p 1 a i n t 1 f f t1:l rJ
another P"otect Ion From Abus"" Crd~r dgainst the
defendant ill Philadelphia,
5, The plaintiff believes ann therAfol'e avers that she 15
1n ImmedIate and present danger of ~buse from the defendant 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 ~ith ths plaintiff
including, but not limited to. telephone and written
communir.ations.
7, The plaint1ff deSIres that the defendant be enjoined
from harassing and stalking the plaintiff, and from harassing the
plaintiff's relatives,
'1, The plaint1ff desires '~lat the defe"dant be restrain8d
from Hntflring her school.
'1. The pl alP,t 1f f deSl res' hat It". rh' f",,::Iant be enJo,ned
frnm '-l"'lTloving. damugl"9, de:..;tt'oj'llltJ or sell1rlg rtny property owned
lOll,t I, by the part,,,,, or owned solely by t,," illa1ntiff,
E\.EXCLUSIVE POSSESSION
n", apartment from vi 11 I (;11 nIL. pl11n'lff
151<.1 ng t tHJ
1(1,
(':\)urt '0 H.e wh~ the defendant 1S rt1'ltHd 'Il 'r.e nilr", 'If Car"a. J.
Royel';' 81 "td'Llln.
'1, flu:, :IBttHldant tlas i\ pf!rmnnent I t:!::;llh'r. ,f:> l~ ;" .~a t10r-ttl
4th Strpp:. Hd!r'l:;tHlrg. DauphIn COLint/1 Pelll,sjl,.';p'" t,
G. ATTORN~Y FEES
1 2 , The p 1 'lltl tiff ask s t hat tile d" f "n <Iii n' I'" ) " <I e r' e d top Ii y
reasnll"t.!e dttcHney fees to Leyal Ser'llc"s, In,..
WHEREFnRE, pursuant to the proviSlnn~ of the "Prutection
from Abu.,,, Act" of October 7,1976,23 Pa,C,S, 96101 et !;~q., as
amended, th" plaintiff prays this Honorable Court to grant the
followiny relief:
A, Grant a Temporary Order pursuant to the "Protection
from Abuse Act:"
1, Ordering the defendant to refraIn from abusing the
plaintiff or placing her in feor of abuse;
2, Ordering the defendant to refra.n from having any
direct or indirect contact with the plaintiff
.ncludlng, but not limited to. telephone Oll(j wr'itten
GOm!nlnl1 cat; ons;
3, Orderlflg the clefelldant to ,!!f,'01l1 frolll harassing
ilnll st;tlllng the pL)!nt1ff and from ',,'lrilS,,"lJ tile
plalt't<ff's relatives;
.1. P!l)!)ibiting ttle defendant (rOf:. e'lt..r1nq tho
pla'Flt Iff's place scltool;
5. r'rohlbi~ing tho defl.ndan' rrl.",tr1 fPrnrj'J,nq, damag1n9,
<1"5'10/"'9 or se11"19 Ilrnp~rtl 1",,"11 ('W"",j by the
PiP-t Il~S Or" owned solely b, tt18 pi i1'l'.' rf;
6, <lldp.rin9 the d"t.Hl.iMlt t,) c;l If <<wili fr,~rn the
IJlh\nt1ff's re5idtJnc~ lo~attJt1 at ..-';'l.lG L CHlla' Run
[II IVl-', Camp Hl11, Cumberland C'-;,Jllty. Penns.,1>';d,"11,1;
7. <),<I"I,ng the defendiwt to stdY dway flo/" dny
1';5,<I..nt." the plaintiff may In th.. fu'urp. ec.tablish f'jr
he,. ~.e 1 f ;
8, Sch",tule a hearing in accordante wIllI ti1U On)v,sions of
the "Protect ion from Abuse Act," and, "lte" such lIearing,
ent"l an order to be in efferl for a pef'lod of one year:
,. Ordering the defendant to refrain from abusing the
plaintiff or placing her in fear of abuse,
2. Ordering the defendant to refrain from having any
direct Dr indirect contact with the plaintIff
including, but not limited to, telephone and written
Gommun,cations.
3, Ordering the defendant to refra,n from harassing
and stal.,n9 the plaint1ff and from haraSSIng the
plaintiff's relatives,
4, o,,)lIibiting the ,jp.fendant fro", "'ltering the
plal~l lff's school.
S, PrDI\1biting the dnfendant flO!11 o,",o'"n.], ,jamaging,
dest "OJ) "'J 0" sell i'1fJ Il,'ope,-ty J<)ir'll Y own.,et by the
P,l" ,",'. ,)f' owned solely by the pla".t 1ff,
,
CARA J, ROGI';RS-IIRADIlAM,
Plaintiff
IN TilE COURT OF COMMON PLEAS OF
CUMDER\.ANlJ COUNTY, PENNSYLVANIA
v,
NO. 95-5144 CIVIL T1;IIM
PARR I SIl T, IIRt\lllIAM,
llefendant
PROTECTION FROM AIIUSE
MOT I ON I'QB CaNT I NUANCJi
The plnintilf moves the Court for an Order continuing
generally the hearing in the above-captioned cnse on the grounds
t ha t :
I, ^ Temporary Protection Order was Issued by this Court on
September 27, 1995. scheduling a hearing for October 5. 1995, at
8:30 a.m.
2. The cumberland County Sheriff's Department served the
defendant with a certified copy of the Temporary Protection Order
and Petition for Protection Order,
3. The defendant indicated to Legal Services, Inc. on
October 4, 1995, that he would enter into a consent agreement.
4. The plaintiff asks that the hearing be generally
continued to afford the parties time to execute the agreement.
5. The plaint i ff requests that the Tempurury Protect ion
Order remuin in effect pending further Order of Court.
6. 1\ cl'rlifie,1 copy of the Order for cuntinuance will be
delivered to the Lowl'r Allen Township police llepartments by the
attorney for the plllintiff.
. "
WIIERE~'ORE, the plaintirf requests that the Court grant this
Motion and continue this matter generally, and that the Temporary
Protect ion order remain in effect unt i I further order of Court,
Respectfully submitted,
( ! --
, ... /;
." cf ,. .' VA I,. '-j:/
~~,.......-'--:"'-..!.....--:::-~~ ---.----...-------.--
Joan Carey, I
Attorney for plaintiff
LEOAL SERVICES, lNC,
R Irvine Row
cnrl isle, PA \7013
(7\7) 243-9400
Cara J, Rogers-Bradham,
plaintiff
IN THE COURT OF COMMON PLEAS OF
v,
CUMBERLAND COUNTY, PENNSYLVANIA
NO, 95-5144 CIVIL TERM
Parrish T, Bradham,
Defendant
PROTECTION FROM ABUSE
PROTECTION ORDER
AND NOW, this ~daY of October, 1995, upon consideration
of the consent Agreement of the parties, the following Order is
entered:
1, The defenrtant, PARRISH T, BRADHAM, SS:136-62-1B74 and
DOB:9/24/62, is enjoined from physically abusing the plaintiff,
CARA J. ROGERS-BRADHAM, and from placing her in fear of abuse.
2, The defendant is ordered to refrain from harassing and
stalking the plaintiff and from harassing the plaintiff's
relatives,
3, The defendant is prohibited from entering the
plaintiff's school.
4, The defendant is prohibited from removing, damaging,
destroying or selling any property owned by the plaintiff or
jointly owned by the parties,
5, The defendant is ordered to enter and complete a drug
and alcohol counseling program and attend relationship
counseling.
6. The court costs and fees are waived.
7, 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 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,
8, This Order may subject the defendant to: i) arrest
under 23 Pa.C.S, S6113; ii) a private criminal complaint under 23
Pa.C,S. S6113,l; iii) a charge of indirect criminal contempt
under 23 Pa.C.S, S6114, 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, S6114,l, Resumption of co-residence on the part
of the plaintiff and defendant shall not nullify the provisions
of the court order,
9. The Lower Allen Township Police Department shall be
provided with a certified copy of this Order by the plaintiff's
attorney and may enforce this Order by arrest for indirect
criminal contempt without warrant upon probabl~ 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 Pa,C.S. S
6113).
Cara J. Rogers-Bradham,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO, 95-5144 CIVIL TERM
v,
Parrish T. Bradham,
Defendant
PROTECTION FROM ABUSE
CONSENT AGREEMENT
This Agreement is entered on this \Q~ day of october,
1995, by the plaintiff, CARA J, ROGERS-BRADHAM, and the
defendant, PARRISH T. BRADHAM, The plaintiff is represented by
Joan carsy 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, Parrish T, Bradham, agrees to refrain
from abusing the plaintiff, Cara J, Rogers-Bradham, and placing
her in fear of abuse.
2. The defendant agrees not to harass and stalk the
plaintiff and harass the plaintiff's relatives,
3, The defendant agrees not to enter the plaintiff'S place
of school.
4. The defendant agrees not to remove, damage, destroy, or
sell any property owned by the plaintiff or jointly owned by the
parties,
5. The defendnt agrees to enter and complete drug and
alcohol counseling and attend relationship counseling,
6. The defendant, although entering into this Agreement,