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Home My WebLink About96-00034 . ' I I , i I \ , 2 ! j! j : ~, , i , i I .,' : I I , I I i I 2 I jt I .J. i' ~J I ! i. to' .' . j \ ~ i i. ~ //J I ~ I 1 ~ ! 0' ! I i I I I I ::r CY) , " ,0- ./ ~i I i I I I I r- ~- .,.. (-,; i''- ... '. ~ :~:I,; t:':~ 0' J n i OJ ~ , lLI:.' . 0", [.., , .. .1_ ~ i ~ ,,---. . ! I.~. . " 'i,1 , .. I, - @:.i~. " ;~'; , ."~ , '.] i5...". , 1.-- , " I.n ( :; .:.... ',' . -:- , TONY I. KOUKOUNAS, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. qLo- >34 CIVIL TERM PROTECTION FROM ABUSE JACKLIN O. KOUKOUNAS, Defendant PETITION FOR PROTECTION ORDER RELIEF UNDER THE PROTECTION FROM ABUSE ACT. 23 P.S. 6101 et seq. A. ABUSE 1. The plelntlff, Tony I. Koukounu, Is an edult Individual residing at 6312 Oxford Circle '6, Mechenlcsburg. Cumberland County, Pennsylvania 17066. 2. The delendant, Jacklin O. Koukounas, Is en edult Individual rasldlng at 4618 Linden Ave.. Mechanlcsburg, Cumber lend County, Pennsylvania, 17056, 3. The delendant II the former wife of the plaintiff and the mother of the partlu' child, 4, Since approximately AugUlt of 1991. when the defendant blcame pregnant, Ihe Indlceted thet Ihe did not want to heve the baby and wented to have an abortion. After being threatened with divorce by the plelntlff, at which time the defendentl temporery relidence Itatul would have been revoked and Ihe would have been lent back to RUllla, Ihe decided to keep the baby. 6. During the courle of the partlel marriage until the plaintiff fl I led for divorce on Mey of 1994. the defendantl actlonl Indicated thaI Ihe did not care to be a wife or a mother to the partlel Ion that .a. born on April 20, 1992. Her actlonl Indlclted pure eelfllhnell for 'u c C I II and ma t e r I I I II tic a quill t Ion I, with hi r h u I ban d be I n g I he mean, to her goall and at the ..me time an obltecle al WII her child. The d.fendant h.1 admitted prevloully and It II ello on court record No 96-6346 that Ih. married the plelntlff only to Itey In the U.S.A. 6. On May of 1994, the delendent willingly geve cUltody of thl pertlu child to the plaintiff, requutlng only e total of fourteen hours to have vllltatlon rlghta, at daYI end hours thel lulted the delendant al the time. 7. Our I ng the time of the per tiel leparetl on, Ihe defendanl again became pregnant by the plaintiff, on or about September of 1994. Upon realizing thll, the defend,nt proceed.d to heve en abortion de.plt. the pl61ntlffl pleal to keep the baby and to try to work Ihlngl oul. On the ..me day that the def.ndant went to the clinic to plrform Ihe abortion, the plelntlff vlllted the court to finalize Ihe pertl'l dlvorc.. 8. Aft.r the divorce the defendant refuled to move out of the apartment. or to ke.p It by herlelf, Blnce the leaee had IUlt been renewed In both nem... In hop.. of reconciliation end Ilnce the plelntlff Itlll loved the defendent, the plaintiff agreed to thele living arrangementl. \- 9. From the time of the par lies separat Ion on Mayo' 1994 the delendant contributed untl I November 01 1994 Ihe emounl of 1400.00 per month towards the household expenses (rent, ut II I ties, clr Insurancal not Including child care e~pen~es or lor food. 10. On November of 1994 the defendent loened the plelntlff the sum 0114,000.00 to be used In the plaintiffs business, at which time she asked the plaintiff to deduct 1400.00 per month from the loan lor her share 01 the household expenses. 11. On May 01 1996 the plalntlll was lorced to file In to blnkruptcy under chapter 7, for his business and also personally. Includad In the plaintiffs bankruptcy the defendent was listed as onl of the cred I tor s. 12. The delendant never accepted the loss and constantly contlnuad to harass the plaintiff lor her money, some of which the p I a I n t III was a b let 0 r e pay and a t I he same tI me h a v I n g t 0 as k the defendant ageln for e loen. On September 01 1996 the plaintiff continued to owe the delendant epproxlmately 14,000.00, 13, On August 30, 1996 the defendant purchased a townhouse where she presently reeldes. 14. On or about September 13, 1996 the plaintiff asked the dllandant to move Irom their Joint epartment, since Ihe had alre.dy purchaaed the house and elnce her behavior bothered the plalntl". The defendant at the time was return I ng to the I r jol n t realdenc. In the early morning houra alter being with her male companlona. 16. On Octomber 8, 1996 the delendant II I led lor a protection Irom abuae order agalnat the plalntlfl and was parllal Iy granted the ord.r liter a court hearing on Octomber 18, 1996 lor alx montha, No 96-6346. 18. During the period 01 Octomber 18, 1996 untl I Dlcember 20. 1996. delplt. the existing order the parties were In contact due to the fact that the defendente mother waa visiting Irom RUllla Ind wanted to apend time with the parties son end also to work out child aupport problema, 17. On or about November 21,1996 the plalnllll canceled hla requ.at lor chi Id support alter the delendent agreed to give up her visitation rlghta In exchange end to cancel the existing PFA order agalnat the plalntl". lB. During the period 01 September 13, 1996 until December 20, 1996 on many occasions the plaintiff ergued with the defendant because 01 her neg II gence. On m.ny occas Ions the par ties aon wo u I d bar e t urn e d tot he pie Inti ff a It e r v I s I tI n g with the dllendant, alck. unproperly fed and on one occasion physlcelly abuled by e dog that resulted In the child being scratched, scared and black and blue just hall an Inch under hla lelt eye, and hla upper lip cut and Iwollen. On another occeslon the child was coached by the delendant to lie to hla father about the presence of the defendanta male companion at her house during the childs visit. 19. On December 14, 1996 the plalntlfl reI used to give the child to the defendant. On the morning of December 14, the plaintiff called the def.ndant end asked her when she picked up the child from the babysitter, not to drive around or to the malls that she normally did lor the purpose 01 shopping for hersell or shopllltlng which she Is In the heblt of doing, because the roads were very slippery alter the snowstorm. The defendant replied with prolanlty and questioned the plaintiffs rights to order her whet to do on her vllltatlon hOUri. The plaintiff Iware of the defendanll driving abllltlea refu..d to give the child In order to avoid endangering the lafety of the child. During her lunch break the defendant arrived at the plalntlfll relldence Ind ltarted pounding on the door, yelling end ullng profane language. The plaintiff opened the door, arguld wi th her end stili refused to give to her the child. 20, On December '8, '996 the defendant called the childs godfather and dur Ing the courle of thel r conversation tho defendlnt wllhed that Ihe hId Iborted tho plrtlol son when sho beceme pregnent with him so that ohe would not be hevlng Iny problems. 2 1. On 0 I C emb er 20, , 996 t hIp ar tI e I me t , 2 : 30 pm a t the office of the AAA In Clmp HIli et which time they both slgnod In the pre..nce of I Notary Public the Stlpuletlon of the pertles that was prepared by the plelntlffs old ettorney, which beclme Court Order on Olcembar 27, '996 No 94-2'87. The plaintiff wee given sole legal end physical cUltody of the parties child. 22. On December 28,1996 tho defendent arrived at the blbYlltlere home at 4:30 pm and ,equealed to briefly visit with thl child. It which time the babYII Iter agreed contrary to the plalntlffl orders and wlshel. 23. On December 28, '996 the defendant In the morning called the plaintiff at his relldence, ullng profane lenguage Ind harrallng thl plaintiff for the purpole of vllltlng the child. Imedl.t.lly following, thl plaintiff called thl lower Allen police D.partm.nt and filled a complaint with officer Morgan. 24. At approximately 4:00 pm when the plalntlfl wal In hll v.hlcle with the parties child getting ready to take the child to the babYII Iter before going to work. the defendant arr Ived It the parking lot of the plllntlfll realdence with her vlhlcll, got out of her c.r andwal provoking the plelntlff to come out of the car. again harrlllng the plaintiff and ullng profane languagl. At t h I I t I me the de fen d ant I act Ion I emo t Ion a II y d I It u r bed the plalntlll and the partlel child. The plaintiff Ignored the defandant Ind proceeded to drive to the babysltterl home from where Igaln hI cllled the lower Allen police Depertment end reported the Incld.nt. After leaving his work early the plllntlff made a formal complaint at 9:30 pm at the lower Allen police Department In the C.pltal City Mall olllce. 26, The plaintiff believes end therefore averl that he and tha partl" child II In Immediate and pre..nt danger of PhYllcal. Plychologlcal and Emot lonal abu" from the defendant and thlt they are Inn e e d 0 f pro t e c t Ion from I u chI bus e . 28. The plalntlll dellres thet the delandant, her relatives and frlendl, be prohibited from hevlng eny direct or Indlrlct contact with thl plaintiff and thl partlel child Including, but not Ilml ted to, te lephonl and wr I tlen commun I cet lonl. ,~ 27. The plllntlff desires that the defendant, her relatives Ind friends, be enjoined from harassing and stalking the plaint Iff and the parties child, end from haralSlng the plaintiffs r,'atlves, and babYII tter. 28. The plaintiff desires that the defendant be enJolnld from damaging or destroying property owned solely by the plaintiff. 29. Thl plaintiff desires that the defendant be restalned from entering his place of employment. B. Schedule I hear Ing In accordance with the provisions of the "Protection from Abuse Act", and, efter such hearing, enter an ordar to be In effect until time the parties child Is old enough to care for his own well-being and to make his own deslclons about visiting wi th his mother: 1, Ordering the defendant to refrain from abusing the plaintiff and the parlles child or placing them In fear of ebuae. 2. Ordering the defendant to refrain from having any direct or Indirect contact with the plaintiff and the parties son Including, but not limited to, lelephone and written communications. 3. Ordering the defendant to refrain from harassing and stalking the plaintiff and the partlee son end from harasslns his relatlvls and blbysltter. 4. Prohibiting the defendant from entering the plaintiff's placel of employment. 5. Prohibiting the defendant from damsglng or destroying proparty owned solely by the plaintiff, 6. Ordering the defendant to stay eway from the plaintiff's preslnt residence or any residence the plelntlff may In the future establleh for himself, The plaintiff further asks that certified copies of this Pltltlon and Order be delivered 10 the Lower Allen Police Department who has Jurisdiction to enforce this Order. The plaintiff prays for such other relief as may be just and proper. Respectfully submitted, '~Lr1-u, t~v...e)~_,<-e.- Tony I. Koukounas, Plaintiff e ~ Q. . a. ].. 1 1L ~ r- ,- a (kJ f-; 0 0 ~ .', 1.11 b .. -;, -. 0 l() - ;::J::': ~...,. r<1 Efti :r: f.J:";,.1 0 lJ) "'I 'fj~ Ie;; -..- If) ,-,:.:, :t- T ~+1 ~f: ,..., ~_:l ~,,~ ad. fit I ~ oil -u :0- 'i 'J CJ F ...::" ~', ;t;..... U. lr:" "j U en [j i. , , /, .' ~; it . TONV I, KOUKOUNAS, Plaint III IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTV, PENNSVLVANIA v. NO . q Lt. - :, "-l CIVIL TERM JACKLIN O. ~OUKOUNAS, Defendan t PROTECTION FROM ABUSE TEMPORARV PROTECTION ORDER AND NOW, thl, dey of January, 1996 upon pre..ntatlon and con,lderatlon of the within Petition, and upon finding that the plaintiff, Tony I. Koukounal, now relldlng at 6312 Oxlord Circle 16, M.chanlcsburg, Cumberland County, Penn'ylvanle, I' In Immediate and pre..nt d.nger of abu,e I rom the defendant, Jack II n O. Koukouna" t h. 10 I I ow I n g Temp 0 r a r y 0 r d er I' en t er e d . The defendant, Jacklin O. Koukounas, now reeldlng at 4616 Llnd.n Av.nue, Mechanlcsburg, Cumberland County, Penneylvanla, I, hereby .nJoln.d from phy,lcally abuelng the plalntltl, Tony I. Koukounal, and the perlle', ,on Vanni, 1. Koukounae, or placing th.m In fear 01 abuse. Th. defendant Ie ordered to stay away Irom the plalntl"', prelant r.,ldenc. and Irom any other re,ldence the plalntlfl may In the lutur. 'Itabll,h lor hlm,ell and lor hi, son, Including the r.,ldance 01 the child', baby,lller. The d.fendant II ordered to reI rain from hav I ng any dl rect or Indirect contact with the plaintiff end the partie', child Including, but not limited to, tel.phon. and wrlllen communication. Th. d.lendant II enjoined from hara"lng and ,talking the plalntltl and the partie', child. The d efe n d ant I' en 10 I n e d from en t er I n g t h" P I a I n tift' , plac., of .mploym,nt. Th. d.fendant I' enjoined from damaging or de,troylng any property owned by the plaintiff. A v I ol.tlon 01 th I' Order may sub ject the defend,nt to: I) ar"lt under 23 Pa.C.S. 6113. II) a private criminal complaint und.r 23 Pa.C.S. 6113.1. III) a charge 01 Indirect criminal contempt under 23 Pa.C.S. 61t4. punl,hable by Imprisonment up to ,Ix month, and a fin. of '100.00-'1,000.001 and Iv) clvl I contempt under 23 Pa.C.S. 6114.1- Thll Order ,halt remain In effect until modified or t.rmlnated by the Court and cen be extended beyond It, original .xpl rat Ion date I f the Cour t "nds that the defendant ha, comml tted an act 01 abu,e or ha, engaged In e pettern or prectlce thet Indlcat.. risk of harm to the plalntlfl or the pertle" child. A hearing shall be held on this matter on the _ day of J.nuary, 1996 at .m., In Courtroom No. _ , Cumberland County Courthouee, Carll,le, Pennsylvanle. TONY I, KOIJKOIINAS, PlaIntiff TN TilE COIJRT OF COMMON PLEIIS OF CIJMFlFRLAND COUNTY, PENW;YLVANIII CIVIi, ACTION - LAW V. JACKLIN O. KOUKOUNAS. Defendol1t 96-0034 CIVIL TERM IN RE; PROTECTION FROM ABUSE ORDER OF ,C QURT AND NOW. this 27nd day of January. 1996. on the petition of Tony I. Koukounas versus JackUn O. Koukounas seeking a protection from ahuse order. IT IS ORDERED; 1. A temporary order is entered this date prohibiting Jacklin O. Koukounos from having ony contact. direct or indirect. with Tony I. Koukounas except for the purposes of exchanging temporary physical custody of their son. Yannis T. Koukounas. under 0 separate order that will be entered this date at 94-2187. and with respect to any emergency situation that may arise with regard to that son. 2. If following a conciliation conference before a conciliator on the current custodY cose plointif~ wishes to pursue the entry of a permanent protection from abuse order. he should notify this Court in writing and a hearing on the merits will be scheduled at which Tony I, Koukounas. 5312 Oxford Circle Mechanicshurg. PA Pro se #5 17055 -- testimony wil~~e Fly the CourY. ~ ~ / / . .I' -E~';B tll" J. '-' token. Thomas M. Kutz, Fscwi re For Defendant ~.... ("M.<~(L ,/ ;j,d 'Ib, )!,. 'f' . :nrs