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Home My WebLink About01-06546 .. ~ ~' "'.....,""'~~, 0" ~ ,.'d _~, ,.' ,', _Jd~""J*r JAMES A. CORDERO PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA V, 01-6546 CIVIL ACTION LAW COLEEN L. ROTHENBERGER DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Monday, November 26, 200t , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqneline M. Verney, Esq. , the conciliator, at 4th Floor, Cnmberland Connty Courthonse, Carlisle on Tuesday, December 18, 2001 at 8:30 AM 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. 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, The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR TIIE COURT, By: Isl ac ueline M, erne Es Custody Conciliator 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 TIDS PAPER TOYOURATIORNEY ATONCK IF YOU DO NOT HA VB AN ATIORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE TIIE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP, Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 ,Wi :~~f~~'W1;Eb\?-mj"!;"f"'~"Nj'~0,j!~,*,~i-.,'1-"d#*"'\il.','1I+~";,';"'"~,, ;:.z,"i0;:""~,l<:iae;!Jf~Jl~~<!.t?&iO~~!iW~!IllIiijilWI'ti~_A""*'J;!1>\it_~Jljj_1II 50 ~ r or-~ ~ ~ ~ ~~- ~,,~ "' ~ :i;i ~ r. 1 "t ~ ~'l ~, '. 1 ' \t . \. $ - " r ~ ; t II, ~.... 0 CJ .. ~: c ~. - - ,.,!~- -00: C) I~: ,"'~ - N ..;"j'j 'J '~L-' -\ , .,j kG -0 "C -rL d-2:C; ..-:& ~~?\ -(~C r::? >c: 7 ,'V ~ :2 (/1 '-< Q= 2.f llJ ,~ , *-.1 <> - t:~ ~~1<<:h",',n,:,I!9',"=. _ ,~J.L~ ,,'~'" ,-"''''''''--~,-,,,,,,,_,, ,'~,' ,'",,,,_,,,o,,,,..,~.,,t.,.j;'tL,,.t,,,:, J'~'M'''~', . , " ,~, 1 ~,~ 0 , . __'"" ' .'<. - ", 01 ~"7" ",.10"'\,'"0'",,',0' ",,~--. -... -..-'''...- L", . -- i -'-"'~'o,_ .;.".. ~.~"; ,,~,~, ~ ,~, "., ~"'i",:",~'J,~;,.;,,~~ ;~,:,,/;~ "'''';(, ~'''.J.&"'' "'-~'7-i!Jt HAROLD S. IRWIN, III, ESQUIRE ATTORNEY ID NO. 29920 35 EAST HIGH STREET CARLISLE PA 17013 (717) 243-6090 ATTORNEY FOR PLAINTIFF JAMES A. CORDERO, Plaintiff = IN THE COURT OF COMMON PLEAS OF = CUMBERLAND COUNTY, PENNSYLVANIA . . v. = CIVIL ACTION - LAW COLE EN L. ROTHENBERGER, Defendant = NO. 01 . (, S"l/(,. = IN CUSTODY CIVIL TERM ORDER OF COURT NOW, this day of November, 2001, in consideration of the attached petition, it is hereby directed that the parties and their respective counsel appear before Hubert X. Gilroy, Esquire, the conciliator, on the 4th Floor, Cumberland County Courthouse, on the day of , 2001, 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. Failure to appear at this conference may provide grounds for entry of a temporary or permanent order. Pending further order of Court, neither party shall remove the child from the CommonweCllth of Pennsylvania. By the Court, By: Custody Conciliator 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 Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 Q >''-i-M.," , ':'" '--~" L'--'-, .'1'..'- ""J;,_;L",~;<~\.,;~ ~,.":,,.< ;"d.J;.~,',>;"":" ':'>""'~;'>~1~': JAMES A. CORDERO, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW COLE EN L. ROTHENBERGER, Defendant : NO. 01 - 1.5'4<P CIVIL TERM : IN CUSTODY PETITION FOR CUSTODY NOW comes the plaintiff, James A. Cordero, by his attorney, Harold S. Irwin, III, Esquire, and presents the following complaint for custody, representing as follows: 1. The plaintiff is James A. Cordero, an adult individual residing at 158 North Main Street, Bendersville, Adams County, Pennsylvania 17306, 2, The defendant is Coleen L, Rothenberger, an adult individual residing at 607 North Hanover Street, Carlisle, Cumberland County, Pennsylvania 17013. 3, The parties are the parents of a minor son, namely Jared Alexander Cordero (born June 11, 1992, age 9 years), 4. The child resided with the parties from the time of his birth until sometime in 1996 when the parties separated, Since that time the child has lived primarily with defendant. Plaintiff has enjoyed liberal visitation and partial custody of the child since that time and remains very active in the life of the child. 5. Plaintiff believes and therefor avers that the best interests and permanent welfare of the child require that the parties have joint legal custody of the child, but that plaintiff have primary physical custody subject to specified periods of visitation and temporary custody with the defendant. Plaintiffs position is based upon the following factors: ,l-t; " L" I, ''-''''='-'' , ',,-- '."';>t,.~.,',j~,'..;; '...:, ;;",';"";\";,, ,.;,~,~\'"-"'-<':".,,,~;,/,,;;.-::_' '~"::''-:;~}i! A. The defendant is currently unemployed and living with her sister in Carlisle; however, since the parties separation in 1996, defendant has resided in approximately seven different residences throughout central Pennsylvania, causing the child to move back and forth between various elementary schools. B. The defendant has indicated to plaintiff that following Thanksgiving, she is moving to Connecticut and that she is taking the child with her, thereby cutting off virtually all meaningful contact between plaintiff and the child, C, The child frequently resides with his maternal grandparents due to defendant's various unstable residential and employment situations. During such times, there is absolutely no reason why the child could not be living with his father, plaintiff herein. Plaintiff believes and therefor avers that the maternal grandparents, Robert and Donna Baker, of 660 Easy Road, Carlisle, Pennsylvania, support his present request for custody of the child, D, Defendant has a minor daughter, Kelly E Russell, the custody of whom was recently transferred from the defendant to the child's father in Illinois. E, On the other hand, plaintiff has maintained the same residence for over 20 years and has a single bedroom for the child. F. Plaintiff has stable, responsible employment. G, Plaintiff has arranged with his sister, Rufina Cordero, for caring, responsible childcare for the child while plaintiff is at work. H, Lastly, throughout the parties separation since 1996, plaintiff has maintained a close, loving and happy relationship with his son, the minor child ., , <, -','<',. I'", '>> ""~',' ' , -". " ""',,1,,; ,~, ,:".., ,',' , , ..:,.;---,";';~,",S,;;",:",;~,,,jj,;~~,,,, ',;; ,,~ ':"Jiili.m:"'! herein, spending substantial time with him on a verbal, liberal visitation and temporary custody arrangement between the parties. 6. 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, 7. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the child or claims to have custody or visitation rights with respect to the child. 8. Plaintiff believes and therefor avers that the best interests and permanent welfare of the child require that the custody of the child be established as aforesaid. In addition, however, due to the defendant's stated intention to move the child from this jurisdiction to Connecticut, thereby effectively preventing plaintiff from maintaining regular contact with the child, plaintiff suggests that this Court should enter an immediate Order providing that neither party remove the child form the Commonwealth of Pennsylvania pending final disposition of this matter. WHEREFORE, plaintiff respectfully requests that the court enter an order providing for the legal and physical custody of the child as aforesaid. November 11, 2001 HAROLD S. IRWIN, II Attorney for plaintiff 35 East High Street Carlisle, Pennsylvania 17013 (717) 243-6090 Supreme Court 1.0. No. 29920 ,-, '" "'..,) " ~. I' _,1- ".1-<- '~', '-.iy: ':;.ltiu :;.i';"'d,tb)""":;,;i"';.~io,,c"',j;:"- ,'",,_;--' :,~:;: VERIFICATION I do hereby verify, that the acts set forth in this petition are true and correct. understand that false statements herein are made subject to the penalties of 18 Pa,C.S. Section 4904, relating to unsworn falsification uthorities. November 4-, 2001 *Ji.Il~' '1il!i~~''''wiil'~j_''';;'dji'(' ',i"",~tlli!!l~j1:,i~ftt~~'_~. "lo~' "''-~ .''_c-;,,-. ~ f " ,,,,~,,,'",,,,,,,,,,""' ~'''' -> .,~,' ~i1 ~. ,." 0 (:::J. ('':' v~~ -fl ;:::e n~!(h ;=:l ~i' .- f',) ,:::> <,-) > ~'> ,-'~ -,,< :z: l.. .I ----',,~ ;;;0 c 9 2: =< ,;:) '0 " ,~, '" ,. .. ' . ,~ -,,,,,~,_"V.~~_" , 1,:W;_~Il= ~~ ~- ',. ~, ' ~.. ' ""'~,~ ",,' ;, '.'~~~ "" '. . }"'"'l!l~~' , II. JAN 1 0 2U02 V JAMES A. CORDERO, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA : CIVIL ACTION -LAW COLEEN L. ROTHENBERGER, : NO. 2001-6546 CIVIL TERM Defendant V. : IN CUSTODY ORDER OF COURT AND NOW, this / 7'"tIJ day of 1JA IIIu.A J , 2002, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. A Hearing is sche~ed in Court Room No, ~, of the Cumberland County Court House, on the.J.Olfiday of mARt" ,2002, atl:.3<J o'clock, tL. M., at which time testimony will be taken, For purposes ohhis Hearing, the Father shall be deemed to be the moving party and shall proceed initially with testimony. Counsel for each party shall file with the Court and opposing counsel a Memorandum setting forth each party's position on custody, a list of witnesses who will be expected to testify at the Hearing and a summary of the anticipated testimony of each witness. These Memoranda shall be filed at least ten days prior to the Hearing date, 2. Pending further Order of Court or agreement of the parties, the following shall remain in effect: 3, The Father, James A Cordero, and the Mother, Coleen L Rothenberger shall have shared legal custody of Jared Alexander Cordero, born June 11, 1992, Each parent shall have an equal right, to be exercised 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 his health, education and religion, 4, child, 5, child: A, B- C, The maternal grandparents shall have primary physical custody of the Father shall have the following periods of partial physical custody of the Every weekend from Friday to Sunday or Monday depending on the child's school schedule at times arranged by Father and the grandparents, Liberal times during the week Such other times as the parties agree, -. "_..."",,,-,...~~_. "~~~............. ' , J lii!IBW~.~.."J o , ,,",' ~~ ~ , .,n' ,-, .;.'i:i"..Wlw.~~\' '.. 6, Mother shall have partial physical custody of the child one weekend per month provided she give maternal grandparents and Father one week prior notification, 7, Father shall provide transportation for his periods of custody; Mother shall provide transportation for her periods of custody, 8, Neither parent shall do or say anything nor let anyone in the child's presence to say or do anything that may estrange the child from the other parent, injure the opinion of the child as to the other parent or hamper the free and natural development of the child's love and respect for the other parent 9, The parties may modifY this Order by mutual agreement In the absence of mutual consent, the terms of this Order shall control. J cc: Harold S. Irwin, III, Esquire, counsel for Father Coleen L Rothenberger, pro se 19 Deerfield Road Waterford, CT 06385 . )~ ~ I, ,),2,0)..- CJ, , ,- ,-- ','~' .," ~ ~".~"" - ,'~" ""..~ ~" ~ '-~'-,...,~.,-,,,,",' ~ "~". -'~-' ~,-~,~' c:- j~ '--,;f/":[I ''\ - '''''-~lt;a7:rr'f.'''- . 1~i '\"i."' ,:' ,-~, . 021!J,,'N07A8Y , ,iT; 18 ",. , C '''I ':J UlV/Sr:.r: '. ":< S PfN~B~'1; COL/fI{"_ vANIA' I r ... .w"' _, ,~,~~~~~!iI!~_~_~~j'~.;W'"I,;~1:W1;i-~'!f.~FHIf ",/~,,'''' '''';""!f~''W!l'i'\-'''*0i1''Wi'i?TH'''!1i:N;;I~WJ1i:>1i:>J:;';;;;-;;:j\1r;~~~, til"--~ '~-,"..,~~~,~.,,~ ~~ .ao..,,' ". I~ I.""""~""",,,..,,,.- "L~ .~~_". ~". " -<. . OJ, .~t])',~l;:;'; ~. JAMES A. CORDERO, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW COLEEN L. ROTHENBERGER, : NO. 2001-6546 CIVIL TERM Defendant V. : IN CUSTODY PRIOR JUDGE: None CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: L The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Jared Alexander Cordero JuneH,1992 maternal grandparents 2, A Conciliation Conference was held January 9, 2002 with the following individuals in attendance: The Father, James A. Cordero, with his counsel, Harold S, Irwin, Ill, Esquire, and the Mother, Coleen L Rothenberger, pro se, 3, Father's position on custody is as follows: Father seeks shared legal and primary physical custody of the child, Mother has moved to Connecticut, and would have taken the child with her except that Father protested the removal of the child from the state. Mother then placed the child temporarily with her parents so that the child could continue in the same school. Father is willing to permit the child to remain in the same school until the end of the school year so as not to disrupt his education, however he objects to the child moving to Connecticut Father presently has liberal partial physical custody of the child every weekend and several evenings a week He fears that if the child moves with Mother, he will lose the close relationship he presently has, 4, Mother's position on custody is as follows: Mother seeks shared legal custody and primary physical custody with Father having one weekend per month, and most of the summer and Christmas vacations, Mother maintains that she has been the primary custodian of the child since birth, although she admits to placing the child with ,~ """""~_~i"""C~ ~ ~ I . ~ ~. . - . .~"--'-"'.'''' ". 'd '~ ""~'~'f'~!c" 'oc her parents periodically when necessary, Mother has moved to Connecticut for a better job. She is currently living with her boyfriend in a three bedroom house, 5, The Conciliator recommends an Order in the form as attached scheduling a Hearing and granting the parents shared legal custody, with the Grandparents having temporary physical custody of the child, with Father having partial physical custody of the child every weekend from Friday to Sunday and liberal custody during the week as arranged with the grandparents, Mother shall have partial physical custody of the child one weekend per month provided she give Father one week prior notice of exercising said right. It is expected that the Hearing will require one day, I - 9 -02.. Date M.~ . acq ine M. Verney, Esq~ Custody Conciliator -~ ~<., - 'N' ' _ .,', '~;\,- ". "'-", 'x'.,,'. , '.~_ .', i,~ , "' ~".,-",',I,,,,;;r- ':"^",,',j' ',-,',C] "'-,,," ,,-,'i(,"'" ~~,,~b"-')l"''-;'::;,~, ',i" , '., '''.' ~,~;, " 'ij, . " HAROLD S. IRWIN, III, ESQUIRE ATTORNEY ID NO. 29920 35 EAST HIGH STREET CARLISLE PA 17013 (717) 243-6090 ATTORNEY FOR PLAINTIFF JAMES A. CORDERO, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. = CIVIL ACTION. LAW COLEEN L. ROTHENBERGER, Defendant : NO. 01 . 6546 CIVIL TERM : IN CUSTODY ORDE'R OF COURT AND NOW, this ~ day of March, 2002, upon presentation and consideration of the attached Stipulation and Agreement and upon agreement of the parties, it is hereby ordered and decreed that the attached agreement is made an Order of Court. J, . ~ ~~~R'k to: bert. PLfF a..~. -:IRW i J lE ffV 5;J . If Q ~~, ""So. ~'" ,,"..~~,-'~,,'~c'" ,,,.. ~ ~p,^" ,> ",~,,,,,,,,'~"'""'1,,,,,,.,,. " ," ~" . '''.e, "''''4:' " "'_Y._ '""0':", . .. ~'"'"" " ,.__",<..,~~. "~"n~,~,_" -;"""'''~~' {\:. ,~. (' v._ r'. "'(Ji' iC~0'~jlY 0.' f;~;li R .... r.,."" th' I j , rJ C', f"H; . 1 ;: e!I.",."', . v!'JIDC(iL'\ COU\!'TY Ph^/"""'" '" , -"/',>1 LvANIA ,,'''''~,~'''- ""'o",-:..,;H1J1,~, _",,' ,,~~~~f,i!~.O?);\!!J"l!Ft~~~~~~~~C" "T:;-- "~'~~~i~ ",'" "" '-0" .",~p'",""~ , ","',' " """ " ,,;;,jd~'v," ".;",,-,,,;;;;, '/ ":;&";,.,;,;;':""f,-,:t:",;;;_~~,;,t;:;;'-"",,,,".i " "'~:"", !2di~'J;'~; -- .JAMES A. CORDERO, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : NO. 01 - ,S'"~ CIVIL TERM : IN CUSTODY COLEEN L. ROTHENBERGER, Defendant STIPULATION AND AGREEMENT THIS STIPULATION AND AGREEMENT entered into this 2 J day of March, 2002, by and between JAMES A. CORDERO (hereinafter referred to as "Father") and COLEEN L. ROTHENBERGER (hereinafter referred to as "Mother"), NOW THIS AGREEMENT WITNESSETH THAT: WHEREAS, the Father and Mother are the natural parents of one (1) child, namely, Jared Alexander Cordero (age 9 years, born June 11, 1992); and, WHEREAS, the parties wish to enter into an agreement relative to the custody, partial custody, and support of the child. NOW, THEREFORE, in consideration ofthe mutual covenants, promises and agreements as hereinafter set forth and intending to be legally bound, the parties hereto agree as follows: 1, The parties shall have joint legal custody of the child, 2, The Father shall have primary physical custody of the child, 3. If the Mother moves outside the local area in Pennsylvania, making normal and frequent visitation with the child unfeasible, then Mother shall have '" - . '1' -,' ~- ~"; '. ~ 1 ,,;"<,i,,;',,~I.,i;:-:"; , ,,; .,;,.;,J,"-",:;;", ,'''.C '-k,:'>':.; .,,;:~,,':.',~,- ::,"<:''': "';'1f;1~ to temporary physical custody of the child during the child's summer vacations, from one week after the child's school year ends in June until one week prior to the beginning of the next school year in August and at such other times as the parties may mutually agree. If the Mother, however, continues to reside in the local area in Pennsylvania, then the parties agree that she shall have regular and frequent temporary physical custody and visitation with the child in accordance with a schedule as may be mutually agreed upon from time to time. 4.' Father and Mother shall share visitation on the respective birthdays of the child as arranged by the parties. Father shall always have the child on Father's Day and Mother shall always have the child on Mother's Day. 5. Holidays shall be shared between the parties as mutually agreed from time to time. 6. Both parties shall have reasonable telephone contact with the child while the child is in the other's custody. Neither party shall remove the child from the Commonwealth of Pennsylvania without first obtaining the written agreement of the other party. 7. If the child expresses to both parents a desire to change his primary physical custody from one parent to the other, at such time the parties agree to discuss and agree upon alternative physical custody arrangements satisfactory to both parties and the child. 8. The parties shall keep each other advised immediately relative to any emergencies concerning the child and shall further take any necessary steps to insure that the health, welfare and well being of the child is protected. 9. The parties shall do nothing that may estrange the child from either party or hinder the natural development of the child's love or affection for the other party. = -, , ' ,- ,-" ,- ,"- 1"'_-_. "' j '.:0- " -, _ -;"';" ' _ I ~,-..:r.--~'," ,- ",,-,.,+, >J~i~-~"",..',,"-_~:-~,L<./';';,.'-;-~!'>~".-_; bo"7>_"~,-1:i~>,' ~'".:: ~>:~-;;;~,;;:;! . 10. Any modification or waiver of any of the provisions of this agreement shall be effective only if made in writing and only if executed with the same formality of this agreement. 11. In the event of the breach of this agreement by either party, the non breaching party shall have the right to file a petition for contempt of court and to seek specific performance of the terms of this agreement. All costs, expenses and reasonable attorney fees incurred by the successful party in any litigation to obtain an order of contempt or specific performance of this agreement shall be recoverable as part of the judgment entered by the court 12. The parties agree that in making this agreement there has been no fraud, concealment, overreaching, coercion or other unfair dealing on the part of the other. 13. . The parties desire that this agreement be made an order of Court through the Court of Common Pleas of Cumberland County, and further acknowledge that the Court of Common Pleas of Cumberland County has jurisdiction over the issue of custody of the parties' minor child and shall retain such jurisdiction should circumstances change and either party desire further or require further modification of said Order. Both parties agree that the hearing scheduled for March 20, 2002 shall be canceled, based upon the entry of this agreement. IN WITNESS WHEREOF, the parties hereto, intending to be legally bound by the terms hereof, set forth their hands and sea Al) WITNESSETH: _n ". ,I,,,,,,,, ',-'"-'''';,,,,,- om.>' ,.'_ ,),' ~_.; ] ,,'_;'."~,:.,I'._,[;,i.i-,;;i"~;,;;:~;.I;i'i0;';_;:;;';ih\'"i;~~':h;'''~.i." '";::,,.\-_ "'2''-_ '"",~_:;:_, . COMMONWEALTH OF PENNSYLVANIA :SS: COUNTY OF CUMBERLAND On this, the 2- '^""" day of March, 2002, before, the undersigned officer, appeared JAMES A. CORDERO, known to me ( or satisfactorily proven) to be the same person whose name is subscribed to the within instrument, and acknowledged that he executed this agreement for the purposes therein contained. IN WITNESS WHEREOF, I hereunto sty hand and official seal. (SEAL) Notarial Seal Harold S. IMin III, Notary Public Cartlsla BOlO, Cumbe~and COunty My COmmlsslpn Expires Sapt. 23, 2002 Member, Pennsylvania Association ot Notaries COMMONWEALTH OF PENNSYLVANIA :SS: COUNTY OF CUMBERLAND On this, the ~;ay of March, 2002, before, the undersigned officer, appeared COLEEN L. ROTHENBERGER, known to me ( or satisfactorily proven) to be the same person whose name is subscribed to the within instrument, and acknowledged that she executed this agreement for the purposes therein contained. IN WITNESS WHEREOF, I hereu 0 s my hand and official seal. NoIarIalSaal (SEAL) Harold S. IMin III, Notary Public Ca~lsle BOlO, Cumbe~and Counly My COmmlssipn Expires Sapt. 23, 2002 Member, Pennsylvania Association of Notaries ,,4 ~:1lliiiE~~j~ ~-,",.~.", J~.~1f~~:> ~ _M\lll;1l@j,,-M~~~,~~~~"",,;:'"~U"Ili' L. ~_,~,>~->,..,"__,"" 00" > ",,,,,;;:L-._...,, _" ,~-',." ,,,", ~,_~_'=_,'i',_'___","~<~ ~,~_ " _,~, - ,~" ~ -.:,;,,~, .il c h ~__,",. --',-," '~'"""",, ,- . () C () c: f'V .;;r>- - , lJ '~;: :~ ---_! i'lL," :';C'" Z~]! ::.;;."] Zr-'! co ",. .-=-- ;sa-: :.< I...~' ::,:: ):> C:' - Z .J . , -/~; PC: ry ,"';: '--../ :z ::> ~t.:~ :< en '-:J:J -< "" -"'__<<"d.~","-,,_,,~-,,o ... i,>~'';'<J,;,'~''_~,&,_",;'",''._'.,;,':"i_" :';;':'_ '.iIl'rlil~i::.;" LAW OFFICES OF HAROLD s. 'RW'N~ "' ATTORNEY-AT-LAW HAROLD S. IRWIN, III NATHAN C. WOLF HITNER HOUSE, SUITES 201 and 202 35 EAST HIGH STREET CARLISLE, PENNSYLVANIA 17013 HEATHER A. BARBOUR RHONDA R IRWIN PARALEGALS www.irwinlawoffice.com e-mail: irwinlaw@epix.net 717-243-6090 PHONE 717-243-9200 FACSIMILE March 4, 2002 HON EDWARD GUIDO CUMBERLAND COUNTY COURTHOUSE ONE COURTHOUSE SQ CARLISLE PA 17013 RE: Cordero v. Rothenberger NO. 01 - 6546 CIVil TERM In Custody Dear Judge Guido: The parties in this case have resolved their custody dispute and I have filed an agreement for your review and the entry of an Order. In the meantime, I wanted to let you know that the hearing scheduled before you on March 20lh can be canceled, in light of this agreement. I'm sure that you won't have any trouble finding something to fill into this times lot. Thank you for your cooperation in this matter. ~ Harold S. Irwin, III -",oj