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Home My WebLink About95-06595 '.". ,'-, .. ",',,' ~i' > ~~~' :',_' ':;,:,:'\-.", .. ,1-, (, . ~ '~::~:' ',-, i- ',::~i,;?:: ~,~ ~~\i~fZ-: " "" ,"" .; ~ . /j .'- .1". :- --:~.'~.' '...\~' ';,,~ "'1.. ");; :3 .,-.:{ . .., .- " . ~ " ,'; ': '~d ,,.. ,,,,;, .... ,:':1 ',:' ~'1. . '~~,' J' 3 ,,' <~ '.; ~ ~ J ,....' '. , .' Lt) $ ~ .', ",,- ".:>- ~:-~~~> v , IN THE COURT OF COMMON PLEAS OF , CUMBERLAND COUNTY, PENNSYLVANIA , , CIVIL ACfION - LAW , , NO. 95 - <.0595 CIVIL , , IN DIVORCE SUIANNB 1C, WOODALL, Plaintiff ROBBRT fIOOODALL, Det'endant NO'./!ICI: ro m:n:ND AND CLAIM RIGH'l'S You have been sued in Court. If you wish to defend against the claims set t'orth in the following pages, you must take prompt action, You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annuL~ent may be entered against you by the Court. A judgment may also be entered against you t'or any other claim or relief requested in these papers by the Plaintlt'f. You may lose money or property or other rights important to you, including custody or visitation of your children. When the grounds for divorce is indignities or irretri..:vable breakdown of the marriage, you may request marriage counseling. A list ot' marriage counselors is available in the Prothonotary's Ot't'iae at the Cumberland County Courthouse, Carlisle, Pennsylvania. IF YOU DO NO'./! FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERfY, LAWDlR'S FEES OR EXPENSES, m:FO.Rl!l A DIVORCI: OR ANNULMH:N'l" IS GRAN'l'ED, YOU MAY LOSE 'l'HE RIGH'l' TO CLAIM ANY OF 'l'HEH. YOU SHOULD 'l"AKE 'l'HIS PAPER 'l"O YOUR LAWDlR All' ONCI:. IF YOU DO NO'./! HAVE A LAWDlR OR CANNO'./! AFFORD ONE, GO 'l"O OR fELEPHONE 'l'HE OFFICI: SEll' FOR'l'H BELOW ro FIND OUT WHH:RE YOU CAN GE'l" LEGAL HELP. COURT ADMINISTRAroR CUMBERLAND COUNTY COURTHOUSE CARLISLE, PENNSYLVANIA 17013 TELEPHONE: 717 - 240-6200 ~~~:r.~",~~.w\'<~"";';<,*,~",'i,,,,,,;,,~~'~~~~*""~~F~~j-~;'M,#f~'1~,,~~.t' SUZANNB IC. WOODALL, I IN THB COURT OF CONNON PLEAS OF Plaintiff I CUMBERLAND COUNTY, PBNNSYLVANIA I v I CIVIL DIVISION - LAW . I ROBBRT WOODALL, JR, I NO. 95 - CIVIL Defendant . . : IN DIVORCB ca.fPLAINT Plaintiff, Suzanne IC. Woodall, by her attorneys, Broujos, Gilroy & Houston, P.C., sets forth the following: 1 Plaintiff, Suzanne IC. Woodall, is an adult individual residing at 501 Waggoners Drive, Carlisle, Cumberland County, Pennsylvania. 2 Defendant, Robert Woodall,Jr, is an adult individual residing at 221 Walnut Street, Carlisle, Cumberland County, Pennsylvania. 3 The parties were married on February 25, 1993. 4 There have been no prior actions for divorce or annulment of this marriage. 5 Plaintiff and Defendant have lived continuously in the Commonwealth of Pennsylvania for at least six months prior to the commencement of this action. 6 Defendant has offered Ifuoh indignities to the Plaintiff, his innocent and injured spouse, as to make her life intolerable and condition burdensome. WHBREFORE, Plaintiff requests your Honorable Court to en tel' a deoree divoroing her from the Defendant. re r..;.,,;, ,', . I verify that the statements in the foregoing pleading are true and oorreot. I understand that false statements herein are made subjeot to the penalties of 18 PaCS 4904 relating to unsworn falsifioation to authorities. \ '.- <Y''''-''''', '-.....,~''f'"" ',M~'l~~~_1t' 'l'Ur~;i;:'lI'.if>'" ;"";Y\ilf;('t"t,7:t!t~~11~ ! t 1 -a -a.. - ?r:t; 5? () g, '~!l: 8 lJ) 1 l,.f~,=~ ~ t,r<,rJ;C lri ~6v"-1 lrj @ 0- :p. I".-.r..&:)> 0- 'C)oo.4/:...J ,..... <"""i "!.G-i:- - 0 J;, tr' '-J'.f) - - l.dt:o..u.:;::Z: ~ ~ rr) ,-::I.!'U:=C ~ :- l.o,;.:.,UI~ ~.,~ lJ "" => 1I co ~t...) == ::J ~ <:.I .- ..... . '. . , . . .~. S, 't."E '.' , .,. h , . 1 " . " '. ;~a?>:.~::::~!~'1*~i~~ti~~1:1P' ~1~; .. .':~~~t~l{t}::'T";:;'~: ."\/~f1~~";;~;I;~1E <,&.", """"'''~,'''l;1t-',., ''''" ",'.., '. " ,"";. ' ";'""';"""'':i;;li'f >~",;'" "'h'"",, ",,,,. ?,.,!--~j,""'~V,':"'" "'...'..... " '''',,,,It.~,..,,.,'.cv';''': ~1::'~~~~, ~}ct.:,}. -...,; h''rT~' '';~}.':t.'' ,~_~ '(~'" . .,' ...:..\J';:!!'],1;.......-..~.-~~~..Jt~t:':~,..'.1,...~.J>':c..,,.\ "(", ,/,.:' .''')''_,,; .1'~'~l.",-"J,~>,(..:t ~! (.;).O>':.{lt'-~,'~l...~;t "t-~""':.. '.. ..'",',''',~> ~'". -,,,,,~,; "'rt"<Hq",;"." . '" " ....;;{,,\;;';~:;,...O;;.:;:.~;;;i:<.t:,,:i!J;:,;Z.,;I.~,;.,\. .';: '.:'" '. i ".'. '">":~,,~,!,,hj";""";""tVttl;h"'i'[.:t\":.,. BROUJOs. GILROY IIr HOUSTON Pc. " ..,: . ' j,-~,,\<',;, ',~..:.,' ','.:,.,:.. '~"f.,;..,',.i.,',5.;,'f,,~,,~~..: ~"::..1..-t...:,)"".,..~1..~i.,'..:~.'.~.,.;,..~.'i,,.'.,:.:.'.;.t..,:." -...'}'.:/ '.'. '. 2~.~f7:':7~,TTo'"".~a "~~KY.:7~;~7~.~.~.Nt. W,.70 1701:1' , . .,' < . . ".NOV.".. . '-. . c : . '., ':: ~ - - '~,:::,:L.:!~';:::::'!:'?;:' . . .. .. ''-'' '~,;c_.__...... -':''''Dij;J~~ik_A.j,W.iJii>)';;''''';~''''''4_' , . , , SUZANNB 1C. WOODALL, I IN THB COURT OF CONNON PLEAS 01' plaintiff : CUMBBRLAND COUNTY, PBNNSYLVANIA : v : CIVIL DIVISION - LAW : ROBBRT WOODALL, JR, : NO. 95 - (..59S" CIVIL Defendant : IN DIVORCB : PROTBCTION FROM ABUSE !l'EMPORARY PR07'ECTIVE ORDER AND NOW, this '12 ~.L day of November, 1995, upon presentation and consideration of the within Petition, and upon finding that the Plaintiff, Suzanne IC. Woodall, is in immediate and present danger of abuse from the Defendant, Robert Woodall, Jr., the following temporary order is entered: 1 Robert Woodall, Jr. is hereby enjoined from physioally abusing Suzanne IC. woodall or placing her in fear of abuse. 2 Robert Woodall, Jr. is refrained from having any contaot with Suzanne IC. Woodall, including, but not limited to, contaot with her by phone or contact at her place of employment or current home. It is further ordered that Robert Woodall, Jr. shall not enter the premises at 501 Waggoners Drive, Carlisle, PA where Plaintiff resides nor shall Robert Woodall enter the premises at McDonald's Restaurant looated on Route 11 in Middlesex Township. 3 Thill Order IIhall remain in effeot until a final Order ill entered in this oalle. A hearing is soheduled on the allegations raised in the attaohed Petition to be held on the 4~ day of ~.~'4.J;,. 1995 at 3: 30 ...{L...m in Courtroom ..5:: at the Cumberland County Courthouse, Pennsylvania. 4 The Cumberland County Sheriff's Offioe shall attempt to make service of this Order at the Plaintiff's request but service may be aocomplished by any applicable Rule of Civil Procedure. 5 Plaintiff or her attorney shall provide to the appropriate polioe agencies a copy of this Order. This Order shall be enforoed by any law enforcement agenoy where a violation occurs by arrest for indirect criminal attempt without warrant upon probable cause that this Order has violated, whether or not the violation is oommitted in the presence of the polioe officer. In the event that an arrest is made under this Section, the Defendant shall not be taken to jail but shall be taken without unnecessary delay before the Court ; that issued the Order. When that Court is unavailable, the Defendant shall be arraigned before a Distriot Justice who shall set bail according to the provisions of Chapter 4000 of the Pennsylvania Rules of Criminal Prooedure (35 P.S. 10190). By the Court J. cc: Hubert x. Gilroy, Esquire 1 SUIANNB lC. WOODALL, : IN THE COURf OF CONNON PLEAS OF Plaintiff : CUMBBRLAND COUNTY, PBNNSfLVANIA : v : CIVIL DIVISION - LAW : ROBSRT WOODALL, JR, : NO. 95 - CIVIL Defendant : IN DIVORCB I PROTECTION FROM ABUSE PETITION FOR PR021lCTIV1C 0R.DIllR UN'DER 'l'H1C PRCY.r1CC1.'ION ERClH' ABUSE ACT Plaintiff, Suzanne K. Woodall, by her attorneys, Broujos, Gilroy & Houston, P.C., sets forth the following pursuant to the Proteotion from Abuse Act, 23 Pa.C.S.A. 96101 et seql Plaintiff, Suzanne K. Woodall, is an adult individual residing at 501 Waggoners Drive.. Carlisle, Cumberland County, Pennsylvania. 2 Plaintiff files this Petition for Protection Order pursuant to the Protection from Abuse Act, 23 Pa.C.S.A. 96101 et seq. 3 Defendant is Robert Woodall, Jr. an adult individual residing at 221 Walnut Street, Carlisle, Cumberland County, Pennsylvania. 4 Plaintiff and Defendant are husband and wife having been married on February 25, 1993. 5 The parties do not have any minor children of this marriage. 6 Plaintirt and Defendant separated on or about Ootober 28, 1995 at whioh time Plaintiff vaoated the marital home. Plaintiff and Defendant have remained separated since that time. 7 During the time Plaintiff and Defendant resided together, Defendant conunitted various acts of abuse on the Plaintiff, as the term "abuse" is defined pursuant to 23 Pa.C.S.A. $6102, whioh acts of abuse oonsisted of the following: A. Defendant on numerous ocoasions struok the Plaintiff with his fists and pushed and shoved the Plaintiff. B. On numerous ocoasions, Defendant threatened to kill the Plaintiff. C. On one oooasion of approximately two years ago, Defendant's physioal abuse of the Plaintiff resulted in her reoeiving two black eyes which required medical attention at Carlisle Hospital. D. Defendant has struck Plaintiff on numerous occasions with a billy club. B. Approximately one month ago, Defendant shoved Plaintiff up against a wall with such force as to break a towel rack in the home. F. Within the past few weeks, Defendant shoved Plaintiff and pushed her in the chest causing her pain that lasted a number of days. G. Within the pallt month, Detendant threatened to kill the Plaintiff. H. Defendant has on oooasions threatened the Plaintiff that he would kill her if she ever left him. 8 Plaintitf is in fear of immediate and present danger of abuse from the Defendant. 9 Plaintiff desires that the Defendant be restrained from entering her current residenoe or her place of employment and from having any contact with the Plaintiff. WHBREFORE, pursuant to the provisions of the "Proteotion from Abuse Act", 23 Pa.C.S.A. S6101 et seq, Plaintiff prays this Honorable Court to grant the following relief: A. Grant the Temporary Order pursuant to 23 Pa.C.S.A. S6107(b) that would provide as follows: 1. Require the Defendant to refrain from abusing the Plaintiff or placing her in fear of abuse. 2. Require the Defendant to refrain from having any contaot with the Plaintiff, including, but not limited, to contact with the Plaintiff at her place of employment and contacts by phone oalls. 3. Ordering the Defendant to stay away from the Plaintiff's current residenoe and Plaintiff's h ,'__.ld'.',,"',~.,. '. "~~,,., ,_ \ plaoe of employment. B. Sohedule a hearing pursuant to the termll of the Proteotion from Abuse Aot and, after suoh hearing, enter an Order to be in effeot for a period of one year requiring the same relief as set forth above. Respectfully submitted, Hubert X. Gilroy, Bsquire BROUJOS, GILROY & HOUSTON, P. C. 4 North Hanover Street Carlisle, PA 17103 717-243-4574 'c."" _0,_:.,;,,'.-.,-...,'. I verity that the etatementll in the toregoing pleadi.ng ere true end oorreot. I understand that talse statementll herein are made lIubjeot to the penalties ot 18 PaCS 4904 relating to unllworn fallliLioation to authorities. . . vo en - ...... "" ,.. co = ~>- -<... ....7- la, 'l~.1 (.)~..o- c:.r..l"~ .....~r;n:. 0.--..... . c.;:"" Ot"':'.,.Jcn UJC'...::;::e .....1 ,uJ% ~::t!.l~ ...'5 ~Q ,,' :5 "" .... , I II I' I I .. I SHERIFF'S RETURN - NOT FOUND CASE NOI 199~-0659~ P COMMONWEALTH OF PENNSYLVANIA I COUNTY OF CUMBERLAND WOODALL SUZANNE K VS. WOODALL ROBERT R. Thomas Kline . Sheriff, who being duly sworn according to law. BaYB. that he made a diligent search and inquiry for the within named defendant, to witl WOODALL ROBERT 3R but was unable to locate Him in his bailiwick. He therefore returns the PROTECTION FRO" ABUSE TEMPORARY PROTECTIVE ORDER NOT FOUND . as to the within named defendant WOODALL ROBERT 3R DEFENDANT IS NOT LIVING AT ABOVE ADDRESS. HE IS BELIEVED TO BE OUT OF STATE. 00/00/0000 Sworn and subscribed to before me this .2~ day of 9-..".] 19....!LJ, _ A.D. n lc..... Q 'M..ti,J /I. O,,-r.I '-t; I'rothonot'arY' ' 'I' 18.00 2.80 .00 2.00 $~~.8!D So answers I / er Sheriff'a CoStsl Docketing Service Affidavit Surcharge . . SUZANNB IC. WOODALL, IN THB COURT OF CONNON PLEAS 01' CUMBBRLAND COUNTY, PBNNSYLVANIA CIVIL DIVISION - LAW NO. 95 - bS-'iS- CIVIL IN DIVORCB PROTECTION FROM ABUSB Plaintiff v ROBBRT WOODALL, JR, Defendant ft::HPORARY P.RO!I'ECTIVE ORDER AND NOW, this ddNl day of November, 1995, upon presentation and consideration of the within Petition, and upon finding that the Plaintiff, Suzanne IC. Woodall, is in immediate and present danger of abuse from the Defendant, Robert Woodall, Jr., the following temporary order is entered: 1 Robert Woodall, Jr. is hereby enjoined from physioally abusing Suzanne IC. Woodall or placing her in fear of abuse. 2 Robert Woodall, Jr. is refrained from having any contact with Suzanne IC. Woodall, including, but not limited to, contact with her by phone or contact at her place of employment or current home. It is further ordered that Robert Woodall, Jr. shall not enter the premises at 501 Waggoners Drive, Carlisle, PA where Plaintiff resides nor shall Robert Woodall enter the premises at McDonald's Restaurant looated on Route 11 in Middlesex Township. 3 This Order shall remain in effect until a final Order is entered in this oase. A hearing is soheduled on the allegations raised in the attaohed Petition to be held on the ..2.!!2 day of f)'F,n/'I'A , 1995 at r J:.~') ....E....m in Courtroom '.:L- at the Cumberland County Courthouse, Pennsylvania. 4 The Cumberland County Sheriff's Office shall attempt to make service of this Order at the Plaintiff's request but service may be accomplished by any applioable Rule of Civil Procedure. 5 Plaintiff or her attorney shall provide to the appropriate polioe agencies a oopy of this Order. This Order shall be enforced by any law enforcement agency where a violation oocurs by arrest for indireot criminal attempt without warrant upon probable oause that this Order has 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 not be taken to jail but shall be taken without unnecessary delay before the Court that issued the Order. When that Court is unavailable, the Defendant shall be arraigned before a District Justice who shall set bail acoording to the provisions of Chapter 4000 of the Pennsylvania Rules of Criminal Procedure (35 P.S. 10190). By the Court k:../ r: u.JJ"J.h'j ()21A_ . 1. J. yr.;)/.: (.,..'( FROM fiE..,:Oi'...D lil'[ ;1~ti,)'.i)ny WllEfCOI. I here unto S'~\ my llanO ','! '''',> ';MI 01 said Court a\ Cnrlislc. Pa. .U \l - . \cu. ( c: . t,;;, ,.:):').,,1 day 01 u'/' . 19.:;!..;L..,.. I - ") .' /J.,,,,,l, Prothonotary co: Hubert x. Gilroy, Bsquire SUIANNB IC. WOODALL, : IN THB COURT OF CONNON PLEAS OF Plaintiff : CUMBBRLAND COUNTY, PBNNSYLVANIA . . v : CIVIL DIVISION - LAW . . ROBBRT WOODALL, JR, . NO. 95 - CIVIL . Defendant . IN DIVORCB . : PROTBCTION FROM ABUSB PETITION .IiOR PRcn'ECTIVE ORDER UNDI!lR THE E'lUYl'EC'J!ION FRCM ABUSE ACT Plaintiff, Suzanne IC. Woodall, by her attorneys, Broujos, Gilroy & Houston, P.C., sets forth the following pursuant to the Protection from Abuse Act, 23 Pa.C.S.A. S6101 et seq: 1 Plaintiff, Suzanne IC. Woodall, is an adult individual residing at 501 Waggoners Drive, Carlisle, Cumberland County, Pennsylvania. 2 Plaintiff files this Petition for Protection Order pursuant to the Proteotion from Abuse Act, 23 Pa.C.S.A. S6101 et seq. 3 Defendant is Robert Woodall, Jr. an adult individual residing at 221 Walnut Street, Carlisle, Cumberland County, Pennsylvania. 4 Plaintiff and Defendant are husband and wife having been married on February 25, 1993. 5 The parties do not have any minor children of this marriage. . 6 Plaintiff and Defendant separated on or about ootober 28, 2995 at whioh time plaintiff vacated the marital home. plaintiff and Defendant have remained separated since that time. 7 During the time plaintiff and Defendant resided together, Defendant committed various acts of abuse on the plaintiff, as the term "abuse" is defined pursuant to 23 Pa.C.S.A. S6102, which acts of abuse consisted of the following: A. Defendant on numerous occasions struck the Plaintiff with his fists and pushed and shoved the plaintiff. B. On numerous occasions, Defendant threatened to kill the plaintiff. C. On one oocasion of approximately two years ago, Defendant's physical abuse of the Plaintiff resulted in her receiving two black eyes which required medical attention at Carlisle Hospital. D. Defendant has struck plaintiff on numerous occasions with a billy club. B. Approximately one month ago, Defendant shoved plaintiff up against a wall with such force as to break a towel rack in the home. F. within the past few weeks, Defendant shoved plaintiff and pushed her in the chest causing her pain that lasted a number of days. . r G. Within the past month, Defendant threatened to kill the Plaintiff. H. Defendant has on ocoasions threatened the Plaintiff that he would kill her if she ever left him. 8 Plaintiff is in fear of immediate and present danger of abuse from the Defendant. 9 Plaintiff desires that the Defendant be restrained from entering her current residence or her place of employment and from having any contaot" with the Plaintiff. WHEREFORE, pursuant to the provisions of the "Protection from Abuse Aot", 23 Pa.C.S.A. S6101 et seq, Plaintiff prays this Honorable Court to grant the following relief: A. Grant the Temporary Order pursuant to 23 Pa.C.S.A. S6107(b) that would provide as follows: 1. Require the Defendant to refrain from abusing the Plaintiff or placing her in fear of abuse. 2. Require the Defendant to refrain from having any contact with the Plaintiff, including, but not limited, to contact with the Plaintiff at her place of employment and contacts by phone calls. 3. Ordering the Defendant to stay away from the Plaintiff's current residence and Plaintiff's . . plaoe of employment. B. Sohedule a hearing pursuant to the termll ot the Proteotion from Abuse Act and, after suoh hearing, enter an Order to be in efLeot for a period of one year requiring the same relief as set forth above. Respeotfully submitted, Hubert x. Gilroy, Bsquire BROUJOS, GILROY & HOUS'l'ON, P.C. 4 North Hanover Street Carlisle, PA J7103 7 J 7-243-4574 1.' ,. ,..._',..... I verJ.ty that the statements in the foregoing pleading are true and oorreot. I understalld that false statements herein are made .ubjeot to the penalties of 18 PaCS 4904 relating to unsworn talllitioation to authorities. Su Of'I':.... (" 't" Nal12 I,' " . ..t... ';1/ ~lJ "'f i 1.11" Ii",