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Home My WebLink About00-00141 ... ERIN Q, HAGENEY : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. RICHARD J. HAGENEY : NO, 2000-0141 CIVIL TERM CIVIL ACTION - CUSTODY ORDER OF COURT AND NOW, this 13TH day of JANUARY, 2000, a hearing on Plaintiffs Petition for Emergency Relief is scheduled for Wednesday JanuaJ-v 19. 2000, at 8:45 a,m, in Courtroom # 5 of the Cumberland County Courthouse, Carlisle, Pa. Until said hearing Plaintiff Erin Hageney is granted primary physical custody of the minor child, Emma Hageney, Defendant shall be entitled to supervised visitation as the parties may agree. Richard J. Hageney 312 Bachmanville Road Hershey, Pa. 17033 ~G~ /-11/-00 RI<,g Maria p, Cognetti, Esquire For the Plaintiff :sld RLEO-GFRCE OF THE PROTHONOTARY 00 JI1rl13 PM 3: 41 CUMSER~~D COUNTY PENNSYLVANIA . ERIN Q, HAGENEY, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. NO. c2C500- J 11 CIVIL ACTION - LAW RICHARD J. HAGENEY, Defendant IN CUSTODY ORDER AND NOW this day of , 2000, upon review of the Petition for Emergency Relief, Plaintiff, Erin Hageney, is granted sole legal and physical custody of the minor child, Emma Hageney. Defendant may exercise rights of supervised visitation as the parties agree. This matter is hereby referred immediately to custody conciliation by the court. BY THE COURT: J. REAGER, ADLER & COGNETTI, PC DEBRA DENISON CANTOR, ESQUIRE Attorney 1.0. No. 66378 MARIA P. COGNETTI, ESQUIRE Attorney 1.0. No. 27914 2331 Market Street Camp Hill, PA 17011-4642 Telephone No. [717] 763-1383 Attorneys for Plaintiff ERIN Q. HAGENEY, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v, NO. J In:ro _ I'f ( CIVIL ACTION - LAW RICHARD J. HAGENEY. Defendant IN CUSTODY PETITION FOR EMERGENCY RELIEF AND NOW comes, Plaintiff, Erin Q, Hageney, by and through her counsel Reager, Adler & Cognetti, P.C. and files the following request for emergency relief as follows: 1. Plaintiff is Erin Q. Hageney, an adult individual residing 5240 Joshua Road, Mechanicsburg, Pennsylvania, 17055. 2. Defendant is Richard J. Hageney, an adult individual residing at 312 Bachmanville Road, Hershey, Pennsylvania, 17033. 3, The parties are the natural parents of a minor child, namely Emma Gail Hageney, date of birth, March 30, 1997. 4. On or about November 1, 1999, the parties in the above captioned matter separated. 5. From that date forward, Plaintiff has exercised primary physical custody of 1 the parties' minor child. Rights of partial physical custody have been granted to Defendant. 6. The basis of the parties' separation was Defendant's alcohol and potential drug addiction. 7. Since the time of the parties' separation, Defendant had agreed to seek counseling for his addiction. Plaintiff participated in ALANON, a support group for families of addicted persons, 8. On December 23, 1999, Defendant visited his psychiatrist and then appeared at Plaintiffs home to care for the parties' minor child. 9. Upon direct questioning, Defendant indicated to Plaintiff that no additional medication had been prescribed to him and he was continuing his previous course of treatment. 10. Plaintiff left the minor child in Defendant's sole care and control to attend her weekly ALANON meeting. 11. Upon Plaintiffs return, Defendant was clearly under the influence of some alcohol or drug, 12. Upon questioning, Defendant admitted that he had taken Ativan, which was prescribed by his psychiatrist that same day. 13. Upon examination of the minor child, it was apparent that she was wearing her diaper backwards and was wearing her pajamas backwards. 2 14. Plaintiff examined Defendant's car and determined that he had taken the minor child out in the vehicle. Defendant appeared to have no recollection of said trip. 15. Plaintiffs friend confirmed that she spoke with Defendant immediately prior to his driving to the pet store with the minor child. 16. Plaintiff attempted to persuade Defendant not to drive and to take alternative transportation back to his home. Defendant declined. 17. Upon arrival at his home, Defendant took more Ativan and went driving in his car with the family dog, 18. In the early morning hours of December 24, 1999, Defendant was involved in a head on collision with another vehicle. 19, The family dog was killed in the accident and Defendant had to be cut out of the vehicle, which was completely totaled. 20. The person in the other vehicle suffered unknown injuries. 21. The state police have indicated to Plaintiff that they intend to prosecute Defendant and are awaiting the urine test results. 22. At the encouragement of Plaintiff and his family, Defendant entered an in- patient rehabilitation center on December 29, 1999. 23, On January 3. 2000, Defendant completed five (5) days of rehabilitation and was discharged to an outpatient treatment plan. 3 24. Plaintiff is concerned that Defendant has no control over his drug or alcohol addiction. 25. It is clear that Defendant is unable to care for the minor child and that he put her at great risk by operating a vehicle while under the influence of the prescription drug, Ativan. 26. Defendant clearly put himself and other individuals at risk by choosing to drive while under the influence. The parties are fortunate that the minor child was not in the vehicle at the time of the accident. 27. Plaintiff is fearful that if Defendant is given unsupervised visits with the child that she will be placed at risk again. 28. Concurrently with the filing of this Petition, Plaintiff has filed a Complaint for Custody and Order for Custody Conciliation. WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter a temporary order granting her sole legal and physical custody of the minor child, Emma Hageney. Plaintiff requests Defendant be granted supervised visitation pending further order of court. Respectfully Submitted: Date: January 7,2000 By: It TI, ESQUIRE Attorney I.D. No. 27914 2331 Market Street Camp Hill. PA 17011-4642 Telephone No, [717] 763-1383 Attorneys for Plaintiff 4 , CERTIFICATE OF SERVICE AND NOW, this 7th day of January, 1999, I hereby verify that I have caused a true and correct copy of the foregoing document. PETITION FOR EMERGENCY RELIEF, to be placed in the U,S. mail, first class, postage prepaid and addressed as follows: RICHARD J. HAGENEY 312 BACH MANVILLE RAOD HERSHEY, PA 17033 REAGER & ALDER, P.C. By: co . VERIFICATION I, ERIN Q. HAGENEY, verify that the statements made in the foregoing document, PETITION FOR EMERGENCY RELIEF AND COMPLAINT IN CUSTODY are true and correct to the best of my knowledge. information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S, Section 4904, relating to unsworn falsification to authorities, DATED: 1 IUt \ 00 ES€L-EllL (LLL) =v'UOLL lid '111H dV\l\f.) 133~LS 13)1~\tI'\I Lm M\tllll S^3N~Ollll '~;; '~31all 'II ~30\f3~ "~- >- cu ~ a; <L - t::-- 1.!J ~..,-~ :J ::s n~ ~~~ ';.-, :JC U ""':. d S)f~~; "-- '~ ~ " r-- ,,:.!' (I) " - c, I ~ , L"'_ tll~ I , ~~ :...!..... 0 :-5 c- o 0 ---"'~ , " . " . ... ~ JAN ... " 200/J.W . ERIN Q, HAGENEY, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v, NO. ~()O() 7 /1 J CIVIL ACTION - LAW RICHARD J. HAGENEY. Defendant IN CUSTODY ORDER OF COURT AND NOW, this \ 1\ "DIe(') day of , 2000, upon consideration of the attached Petition, it is hereby directed that the parties and their respective counsel appear before ~ ~l ,,\ ~~ i , Esquire, the conciliator, at 3q \",1, H1\C\,I '*'; ,~~\{\.h-t~ Pennsylvarha, on Qp dv- the ;)::::, day of ~ b ,2000. at ~ o'clocK' -?-.m., for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. Either party may bring the children who are the subjects of this custody action to the conference, but the children's attendance is not mandatory. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. FOR THE COURT, By (~,) 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. Cumberland County Lawyer Referral Service Court Administrator South Hanover Street Carlisle, PA 17043 (717) 240-6200 J. RLED-OFFICE OF WE ~;imHONOTARY 00 J.&N 19 PH 2: 25 CUMBERLAND COUf\llY PENNSYLVANIA j-/,?6"?' W-~ ~""" -;& a4 ~ //r'-ezy ~ ,~h~' J-/l-ocJ ~ ~~ ~ 4 ~~ . REAGER, ADLER & COGNETTI, PC DEBRA DENISON CANTOR, ESQUIRE Attorney I.D. No. 66378 MARIA P. COGNETTI, ESQUIRE Attorney I.D. No. 27914 2331 Market Street Camp Hill, PA 17011-4642 Telephone No. [717] 763-1383 Attorneys for Plaintiff ERIN Q. HAGENEY, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. NO. ..2~ -I'll CIVIL ACTION - LAW RICHARD J. HAGENEY, Defendant IN CUSTODY COMPLAINT FOR CUSTODY AND NOW comes. Plaintiff, Erin Q. Hageney, by and through her counsel Reager, Adler & Cognetti, P,C. and files the following request for emergency relief and Complaint in Custody as follows: 1. Plaintiff is Erin Q. Hageney, an adult individual residing 5240 Joshua Road, Mechanicsburg, Pennsylvania, 17055. 2. Defendant is Richard J. Hageney, an adult individual residing at 312 Bachmanville Road, Hershey, Pennsylvania, 17033. 3. The parties are the natural parents of a minor child, namely Emma Gail Hageney, date of birth, March 30, 1997. 4. Plaintiff seeks primary physical custody of the following child; Emma Gail Hageney, date of birth, March 30, 1997. 5, The child was born in wedlock. 6. The child is presently in the custody of Erin Q, Hageney, who resides at 5240 Joshua Road, Mechanicsburg, Pennsylvania, 17055. 7. The relationship of the Plaintiff to the minor child is that of natural mother. The Plaintiff currently resides with the minor child, 8. The relationship of the Defendant to the minor child is that of natural father. Defendant resides alone. 9. The minor child has been in Plaintiff's custody at 5240 Joshua Road. Mechanicsburg, Pennsylvania, 17055. 10. Since the minor child's birth, the child has resided with the following persons at the following addresses: NAME ADDRESS DATES Erin & Richard Hageney 5240 Joshua Road March 30, 1997 to Mechanicsburg, PA November 1,1999 Erin Q. Hageney 5240 Joshua Road Mechanicsburg, PA November 1, 1999 to present. 11, Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child in this or another court. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. Plaintiff does not know of a person not a party to the proceeding who has physical custody of the child or claims to have custody or visitation rights with respect to the children. 12. The best interest and permanent welfare of the child will be served by granting the relief requested because the child is at great risk for physical harm if allowed to be in Defendant's sole control. 13. Each parent's parental rights to the minor child have not been terminated and the person who has physical custody of the child have been named as parties to this action. WHEREFORE, Plaintiff respectfully request this Honorable Court to enter a temporary order granting her sole legal and physical custody of the minor child, Emma Hageney, Plaintiff requests Defendant be granted supervised visitation pending further order of court. Respectfully Submitted: REAGER, AD Date: January 7, 2000 By: ~ MARIA P. COGN I, ESQUIRE Attorney I.D. No, 27914 2331 Market Street Camp Hill, PA 17011-4642 Telephone No. [717] 763-1383 Attorneys for Plaintiff , , VERIFICATION I, ERIN Q. HAGENEY, verify that the statements made in the foregoing document, COMPLAINT IN CUSTODY are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa,C.S. Section 4904, relating to unsworn falsification to authorities. DATED: llll luO ~~, ERIN Q. HAGENEY ~ , I , I '- I '~, >- 0:: -,' t'::::: -~ W~~ ~~~ ~~_:: ~,t~;: u'" LL-. ..i_ G '" .. ~ , CV) -=t :t: c._ r-- <eo "'-::: co -::J (.:: Z ;<< ()i...~)Z .,- :~;~ :_.re:"5 _.-17 ~~~ :'5 () ~~~ ~ ~ ~\::- ~~~ ~ v ESEL-E9L (LLL> t179v'LLOLL \fd 'lllH d~'!f:) 133~lS 13)l~'o'II\I LEE/: M\fll\f SA3N~Oll\f '~"d 'ij310V 'll ij3!)\f3~ ..... T,- .. . . JAN .:. 0 200() tIJ < ERIN Q. HAGENEY , : IN THE OJURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : vs. : NO. 00-141 CIVIL TERM : : CIVIL AcrION - LAW RICHARD J. HAGENEY, : Defendant : IN CUSTODY aIDER OF COURT AND NC>>I, this 11th day of April, 2000, the Conciliator, being advised by Plaintiff's counsel at the time of the Conciliation Conference that all custody issues have been resolved by agreement of the parties, hereby relinquishes jurisdiction in this case. The_Cust9dx Conciliation Conference scheduled for April 11, 2000 is canceled. FOR THE OJURT, Da~!:? Custody Conciliator f-,'I.ED-Of'?lCE OF T~;: P"'OTHOi~OTNiY 00 ~.PR 20 11M fO: 47 CUMBE.RLi;ND COUNT?'~ PENNSYLVANIA ~ ERIN Q, HAGENEY IN TIlE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PLAINTIFF V. RlCHARD J, HAGENEY 00-141 CIVIL ACTION LAW DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, this 26th day of June , 2000, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before Dawn S. Sunday, Esq. , the conciliator, at 39WestMainStreet,MechanjClibur~IPA17055 ,onthe 1st Hdayof Angnst ,2000,atU:OOAM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to derme and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. FOR THE COURT, By; Isl Dawn S. Sund4J!. ES~.\ Custody Conciliator '-J The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites 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. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE TIlE OFFICE SET FORTH BELOW TO FIND OUTWHERE YOU CAN GET LEGAL HELP. CumbelOland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 ,~'LE~ ~ -F!~- I U-f tl~ . 't OF THe mdi).,o'NOTARY 00 jUri 28 Mill: /2 CU,\18ERLA"ID COUNTY PENNSYLVANIA tJ,-C}-t-15O M-~ ~?i;; ~ j/C)1-a:/ ~ ~/ ~ t:.-,;;.<;:-t:Jt7 ~ h4~ ~ ~ , ~ ~ " ~ ... ERIN Q. HAGENEY, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v, NO. 2000 - 0141 CIVIL ACTION - LAW RICHARD J. HAGENEY, Defendant IN CUSTODY ORDER OF COURT AND NOW, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before Esquire, Conciliator, at the , Pennsylvania, on the day of 2000, at .m., for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or, if this cannot be accomplished, to define and narrow the issues to be heard by the Court, and to enter into a temporary Order. Either party may bring the child who is the subject of this custody action to the conference, but the children's attendance is not mandatory. Failure to appear at the conference may provide grounds for the entry of a temporary or permanent Order. FOR THE COURT DATED: BY: Custody Conciliator YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IFYOU 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. OFFICE OF THE COURT ADMINISTRATOR COURTHOUSE, 4TH FLOOR CARLISLE, P A 17013 (717) 240-6200 ...... ~ - , , ERIN Q. HAGENEY, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA PetitionerlPlaintiff v. NO. 2000 - 0141 CIVIL ACTION - LAW RICHARD J. HAGENEY, RespondentlDefendant IN CUSTODY PETITION FOR CONCILlA TION CONFERENCE AND NOW, comes PetitionerlPlaintiff, Erin Q, Hageney, by and through her counsel, Reager, Adler & Cognetti, P.C" and files this Petition For Conciliation Conference and in support thereof, avers the following: I. The Petitioner is Erin Q. Hageney, the Plaintiff in the above-captioned matter. 2. The Respondent is Richard J. Hageney, the Defendant in the above-captioned matter, 3. The parties are the parents ofthe minor child, Emma Gail Hageney, date of birth, March 30,1997. 4. By Order of Court dated January 18, 2000, the parties were scheduled for a Custody Conference before Dawn Sunday, Esquire. 5. Thereafter, counsel for Petitioner sent correspondence to the Custody Conciliator stating that the parties were negotiating a Custody Stipulation and would like the Conference canceled. 6. The parties were never able to reach an agreement regarding the custody. 7. Petitioner believes and therefore avers that a Custody Conference should be scheduled to resolve the outstanding custody issues. '- '- . ... WHEREFORE, Petitioner respectfully requests that a Custody Conciliation Conference be scheduled for the purpose of resolving the current custody issues, Respectfully Submitted: REAGER, ADLER & COGNETTI, PC Date, June 19,2000 B"'~~ DEBRA DENISON CANTOR, ESQUIRE Attorney LD. No. 66378 2331 Market Street Camp Hill, PA 17011-4642 Telephone No. (717) 763-1383 Attorney for PetitionerlPlaintiff E8EL'E9L (LLL) ~179v-L LOLL \td 'lllH dVII\tJ 133~lS l3~~\tVII LEE~ M\tll\t SA3NHOll\t 'J<l '11l3NDOJ 'll H310\t 'H3D\t3H -- '.!} E; ~ !=: :z: LL!::-.:o.; -J ,~~ Z,);:,-,: ~'" d~ r:- :'t-: is: (".-Jp-.; 0:':; ;;0;>- CCr~-: :SO') N . Z " Z it.: :z: - ::::, ~HtU -., , ,,- l~L 0 & :() CJ -, '. " ~ .' ~ ....." - , ..... .-. JUN 22 200n \ ~ "" ,(' ERIN Q. HAGENEY, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUl-lTY, PENNSYLVANIA : vs. : NO. 00-141 CIVIL TERM : RICHARD J. HAGENEY, Defendant : CIVIL ACTION - LAW : IN CUS=Y ORDER OF CClURT /7H1 upon consideration of the attached ordered and directed as follows: AND NCM, this day of ()~ , Custody Conciliation Report, 2000, it is 1. The Mother, Erin Q. Hageney, and the Father, Richard J. Hageney, shall have shared legal custody of EImna Gail Hageney, born March 30, 1997. Each parent shall have an equal right, to be exe=ised jointly with the other parent, to make all major non-emergency decisions affecting the Child's general well-being including, but not limited to, all decisions regarding her health, education and religion. 2. The Mother shall have primary physical custody of the Child. 3. The Father shall have partial physical custody of the Child on alternating weekends, beginning October 6, 2000, fran Friday when the Father shall pick up the Child from daycare through Monday when the Father shall return the Child to daycare. In addition, the parties agree to be flexible and cooperative in making adjustments to the weekend periods of custody and also in scheduling additional daytime and evening periods of custody f= the Father when he is in the Mechanicsburg area at least one time per week. 4. The parties shall alternate having holidays as follows: custody of the Child on A. CBRJ:S.rMAS: The Christmas holiday shall be divided into Segment A, which shall run fran December 21 at 12:00 noon through Christmas Day at 12:00 noon, and Segment B, which shall run frcm Christmas Day at 12:00 noon through January 1 at 12:00 noon. In even numbered years, the Mother shall have custody of the Child during Segment A and the Father shall have custody during Segment B. In odd numbered years, the Father shall have custody of the Child during Segment A and the Mother shall have custody during Segment B. B. ALTERNATING HOLIDAYS: The parties shall alternate having custody of the Child on Easter, Memorial Day, July 4th, Labor Day and Thanksgiving each year, beginning with the Father having custody over Thanksgiving in 2000. The holiday custody period shall include the full weekend which falls either immediately preceding or following the holiday. In the event July 4th falls in the mid-week, the holiday shall include at " ,> least one overnight. C. The holiday custody schedule shall supersede and take precedence over the regular custody schedule. Unless otherwise agreed between the parties, the regular alternating weekend schedule shall continue on an ongoing basis without adjustments for weekend, periods of custody missed by either party due to the holiday schedule. 5. Each party shall be entitled to have three non-consecutive one week periods of uninterrupted custody with the Child each year. Unless otherwise agreed between the parties, neither party shall schedule a period of vacation custody under this provision to interfere with school after the Child reaches school age. 6. The parties shall share the responsibility for providing transl?Ortation for exchanges of custody as arrangea by agreement. 7. This order is entered pursuant to an agreement of the parties at a CUstody Conciliation Conference. The parties may modi.fy the provisions of this order by mutual consent. In the absence of mutual consent, the terms of this order shall control. J. cc: Debra Denison Cantor, Esquire - Counsel for Mother Samuel L. Andes, Esquire - COunsel for Father, t~ , j{)- J7-()O RX3 F!LED-DFFiCE OF T'-i<; P?/Yf.HONOTAHY 00 OCT I 7 AM 8: 50 CUM8ERlA!\D CbUNTY PENNSYLVANIA ERIN Q. HAGENEY , : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : vs. : NO. 00-141 CIVIL TERM : RICHARD J. HAGENEY , : CIVIL ACTION - LAW Defendant : IN CUSTODY CUSTCVY CCIllCILIATICN SUMMARY REPCRT IN ACCaIDANCE WITH ClJMBEmJ\ND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned CUstody Conciliator submits the following report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN COS'lOOY OF Enuna Gail Hageney March 30, 1997 Mother 2. A Conciliation Conference Was held on october 3, 2000, with the following individuals in attendance: The Mother, Erin Q. Hageney, with her counsel, Debra Denison Cantor, Esquire, and the Father, Richard J. Hageney, with his counsel, Samuel L. Andes, Esquire. 3. The parties agreed to entry of an Order in the form as attached. Date r0rh~A V; duOI') a~~n4 Dawn s. sunday, Esquire J CUstody Conciliator RLED-G-1\C: OF Tt -:1: PhQTHCrt\;OT!~Y 00 OCT I '1 AM 8: ,,9 CUMSERU0iD COUNT{ PENNSYlVANLlI, .~, REAGER, ADLER & COGNETTI, PC ATTORNEYS AND COUNSELORS AT LAW 19 -?J31 2331 MARKET STREET CAMP Hill, PENNSYLVANIA 17011-4642 717-763-1383 TElEFAX 717-909-4333 WEBSITE: ReagerAdlerPC,com THEODORE A. ADLER + DAVID W, REAGER MARIA p, COGNETTI ++ LINUS E. FENICLE DEBRA DENISON CANTOR THOMAS O. WilLIAMS SUSAN H. CONFAIR JULIE A. McCONAHY .. Certified Civil Trial Specialist ++ Fellow. American Academy of Matrimonial Lawyers Writer's E-Mail Address:ddenison@epix.net January 18, 2000 via FACSIMILE and FIRST CLASS MAIL Honorable Judge Edward E. Guido Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 RE: Hageney v. Hageney o. 2000-0141 Action in Custody Our File No. 99-839 Dear Judge Guido: This letter is follow up to my secretary's message to your chambers oftoday. Sam Andes is representing Defendant Richard Hageney in the above captioned matter. It is my understanding that we have come to an agreement as to a temporary custody order in this matter. We are in the process of obtaining the signatures of our clients on the proposed Stipulation and will submil that to your chambers upon finalization. Based on this understanding of a settlement, we are requesting that this matter be continued generally pending an entry of an order. Your attention is appreciated. , ~ DOC/ems Enclosure CC: Erin Hageney Sam Andes. Esq,(via Facsimile) e1!18!2eee 15:29 2325775 MARIA P COGNETTI ESQ PAGE 02 .. ~~ ... REAGER, ADLE.R & COGNETTI, PC ATIORNEYS AND COUNSELORS AT LAW ; . 2331 MARKET STREET CAMP Hill, PENNSYLVANIA 17011-4642 717-763-1383 TELEFAX 717,90l>-4333 WEBSlTE: ReagerAdlerPC,com THEODO~ A. ADLER + DAVID W. REAGER MARIA P. COGNeTTl++ LINUS E. FENICLE DEBRA DENISON CANTOR THOMAS 0, WILLIAMS SUSAN H. CONFAlR JULIE A. McCONAHY .. Certified Civil Trial Speelalllll +. Follow, American Aeademy or Ml;iltrlmonial Lawyers. Wtiter"a E-Mail Addl'l3lllil; ddenl$Qn@epb.:.nst January 18, 2000 ..03 FACSDMILE and FIRST CI ASS MAIL Honorable Judge Edward E. Guido Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 RE: HaOelUL1l1l. Haaenev ........... -_...........n._-.#-..... -L__ Dear Judge Guido: This letter is follow up to my secretary's message to your cnambers of today, Sam Andes is representing Defendant Richard Hageney in the above captioned matter. It is my understanding that we have come to an agreement as to a temporary custody order in this matter. We are in the process of obtaining the signatures of our clients on the proposed Stipulation and will submit that to your chambers upon finalization. Based on this understanding of a settlement, we are requesting that this matter be continued generally pending an entry of an order. Your attention is appreciated. DDC/cms Enclo8ure ~ cc: Erin Hageney Sam Andes, Esq.(via Facsimile) 01/18/2000 16:29 2325775 MARIA P COGNETTI ESQ PAGE 01 , .~ ~ " REAGER ADLER & COGNETTI, PC A TTORNEYS AND COUNSELORS A T LA W 2331 Market Street Camp Hill, PA 17011-4642 Telephone: (717/ 763-1383 Telef8X: (717/ 909.4333 Theodore A, Adler David W. Reeger Maria P. Cognetti LinusE, Fenicla Debrl!l Denison Cantor Thomas 0, Wl1liams Susan H. Con fair Julie A. McConahy FACSIMILE COVER SHEET To: Honorable Judge Edward Guido From: DEBRA DENISON CANTOR Fax No.: 240-6462 Date: January 18, 2000 Same to FoUow by Mall: Yes Pagers) to FoUow: 1 Message: RE: HAGENEY v. HAGENEY No. 2000-0141 Please see the attached lettel:'. Please can Charlene at (717) 763-1383 If there Is any problem In transmission. Tbe information coDtaIned In this telefac:dmUe is transmitted. by an attorney. It it privileged and confidential, IntlElJ.ded on.ry for the: use of tbe lbdlvldull or ent:l.l)' named aboVL If tbe rude.. of tbls musABe 'e D.ot th.e Intended rulplent. you are hereby notl1led that any disseminatlQn, distribution or copyin&: ollbis ~mmuIli(:.tion is Itridly probiblted. If tbis comnlutdcation has been n.cdved lo error) plcuc l.mmcd:1atcly D.olify us by tcJep"oD.1C, ~onc:ct 1fDcc~~ary, and rll:'tu.rn the oril;bull mCSSR&e to us....t the above 1I.4dJ'l;ls$ Vla Ute U.S. rami Servtce (we will reimbune po...,e). Tballk you,