HomeMy WebLinkAbout12-1385JAMES P. HASENJAEGER,
Petitioner
vs.
WHITNEY L. HASENJAEGER,
Respondent
Prior Judge: Christy Lee Peck, J.
IN THE COURT OF COMMON PLEAS rnc7
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CUMBERLAND COUNTY {' T
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No. 12- 1385 Civil Term: `
PRAECIPE TO WITTHDRAW PETITION FOR SPECIAL RELIEF FOR EXCLUSIVE
POSSESSION OF THE MARITAL RESIDENCE
1. Petitioner is James P. Hasenjaeger, (hereinafter referred to as "Husband") a competent
adult individual, who resides at the marital residence located at 519 Terrace Drive, New
Cumberland, PA 17070 with Respondent Whitney L. Hasenjaeger ("Wife").
2. Husband and Wife are currently attempting to resolve any differences between them
amicably.
3. Husband hereby requests that the Petition for Special Relief in the instant matter be
dismissed without prejudice.
WHEREFORE, Petitioner/Husband requests this Honorable Court to allow him to
withdraw his petition and to dismiss said petition without prejudice.
Respectfully submitted,
Date: ------
/ Jo gan, Esquire
YD. 1'Po.87000
(17 W. South St.
Carlisle, Pa. 17013
(717) 241-2446
ATTORNEY FOR PETITIONER
VERIFICATION
John Mangan, Esquire, states that he is the attorney for James Hasenjaeger in this action;
that he makes this affidavit as attorney because he has sufficient knowledge or information and
belief, based upon his investigation of the matters averred or denied in the foregoing document;
and that this statement is made subject to the penalties of 18 Pa. C.S. Pa.C.S. §4904, relating to
unsworn falsification to authorities
Date: ?'/IC??IZ
/Jo Mangan, Esqui
l` Attorney for James Hasenjaeger
JAMES P. HASENJAEGER, IN THE COURT OF COMMON PLEAS
Petitioner CUMBERLAND COUNTY, PENNSYLVANIA
vs. No. 12- 1385 Civil Term
WHITNEY L. HASENJAEGER,
Respondent
Prior Judge: Christy Lee Peck, J.
CERTIFICATE OF SERVICE
I, John Mangan, Esquire, do hereby certify that I served a copy of the Praecipe to
Withdraw upon the following by depositing same in the United States mail, postage prepaid, at
Carlisle, Pennsylvania, and/or personal service as follows:
George Mantangos, Esquire
John Mangan, Esq.
Sean Shultz, Esquire
Cindy Villanella, Esq.
Lindsay Baird, Esq.
Date: 1& ?Z1L_
Respectfully submitted,
BAYL?EJY & MANGAN
Jol J. /Iangan, Esquir;'
17 W?st South Street ?
Carlisle, PA 17013
(717) 241-2446
Supreme Court I.D. # 87000
JAMES P. HASENJAEGER, IN THE COURT OF COMMON PLEAS
Petitioner CUMBERLAND COUNTY, PENNSYLVANIA
vs. No. 12- 1385 Civil Term
WHITNEY L. HASENJAEGER,
Respondent
Prior Judge: Christy Lee Peck, J.
ORDER OF COURT
AND NOW, this / --bt day of April 2012, upon consideration of the within Praecipe
to Withdraw Petition, the Petition is hereby DISMISSED without prejudice.
BY THE COURT:
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cc: orge Mantangos, Esquire
? John Mangan, Esq.
Shultz, Esquire
Villanella, Esq.
Baird, Esq.
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JAMES P. HASENJAEGER,
IN THE COURT OF COMMON PLEAS
2M
Petitioner CUMBERLAND COUNTY, PENNSYLVAgi,
VS. No. 12- ?38 Civil Term e o
x C)
WHITNEY L. HASENJAEGER,
Respondent
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PETITION FOR SPECIAL RELIEF FOR EXCLUSIVE POSSESSION OF THE
MARITAL RESIDENCE
1. Petitioner is James P. Hasenjaeger, (hereinafter referred to as "Husband") a competent
adult individual, who had resided at the marital residence located at 519 Terrace Drive, New
Cumberland, PA 17070 until 02/26/12.
2. Petitioner currently is staying in a motel.
3. Respondent is Whitney L. Hasenjaeger, (hereinafter referred to as "Wife"), an adult
individual, who currently resides in the marital home, which is located at 519 Terrace Drive,
New Cumberland, PA 17070.
4. The Petitioner and Respondent are married and have one child, Erin Hasenjaeger, born
11/06/1995.
5. There was an emergency hearing at Cumberland County Children and Youth
Services on Thursday 02/23/12 as a result of certain allegations against Mother regarding
daughter.
6. At the conclusion of said hearing, Wife agreed to vacate the marital residence and
let Husband remain there in anticipation of Erin returning to her Father's care.
7. Erin is currently in temporary foster care.
8. Mother is to have no contact with daughter pending further hearing or Order of
Court.
9. The daughter underwent a Children's Resource Center interview Monday
02/27/12 regarding possible abuse perpetrated by Mother.
10. There is a pending Children and Youth abuse investigation as well as a state
police investigation regarding possible abuse perpetrated by Wife on her daughter.
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11. Petitioner needs to have exclusive possession of the marital residence so that his
daughter, Erin, can leave foster care and return to his care.
12. Due to his extreme concerns regarding his daughter, Husband is requesting that
the court direct Wife to vacate the marital residence so that he may have exclusive possession
and have his daughter return home.
13. The Child's Guardian Ad Litem, Cindy Villanella, Esq. concurs with this request.
Lindsay Baird, for Children and Youth, has been contacted but was unavailable to offer a
position, Sean Shultz, Esq., court appointed counsel for Mother does not agree with this request
and George Mantangos, private counsel for Mother has been contacted but was unavailable to
offer a position.
WHEREFORE, Petitioner/Husband requests this Honorable Court to direct Wife to
vacate the marital residence so that he may have exclusive possession of said marital residence
Respectfully submitted,
Date:
J;Al? gan, Esquire f
o. 87000 ///
7 W. South St.
Carlisle, Pa. 17013
(717) 241-2446
ATTORNEY FOR PETITIONER
VERIFICATION
I verify that the statements made in this Petition are true and correct. I understand that
false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn
falsification to authorities.
Date: ?? / James Hasenjaeger, Petiti