Q: What reason did Hepburn give to the court for striking the February 29, 1988 hearing?
A: The reason given by Hepburn for striking the hearing was because of her concern that I hadn’t received notice and therefore she couldn’t be sure that I was aware that there was a hearing scheduled for that morning.
Q: Was this claim made by Hepburn to the court true?
A: If I didn’t know about the hearing how could I have known to phone Det. Chapin that morning and give a recorded statement! And, if she didn’t know about my forwarding address information how could Det. Chapin known to have contacted my friend to whom my mail was being forwarded!
Q: Was custody of Doni automatically restored to me when Hepburn struck the February 29th hearing?
A: Yes. That is how the law relative to show-cause custody motions work, and Hepburn was fully aware that custody of Doni was restored to me when she struck the hearing on February 29, 1988.
Q: How do I know that Hepburn was fully aware that custody of Doni had been restored to me as a result of her striking the hearing on February 29, 1988?
A: Because on that same day—February 29, 1988—Hepburn filed a fourth petition seeking custody of Doni. Why the need to file a fourth petition for custody unless you know your client no longer possesses custody under the February 17th temporary order?
Q: Did Det. Chapin withdraw his request for a Custodial Interference charge against me since custody had been restored to me?
A: No. The filing of this criminal charge continued to be actively pursued by Det. Chapin, Hepburn, and Don.
Q: When was Don’s fourth petition for custody scheduled to be heard?
A: March 7, 1988—another hearing date noted by Hepburn with less than the requisite ten-day’s notice requirement and without an Order Shortening Time.

There was no attempt made by Hepburn to obtain temporary custody of Doni for the period of time existing between February 29th and March 7, 1988.

Q: Given the claim made by Hepburn to the court for striking the February 29, 1988 hearing, and given the fact that she knew my forwarding address information, was notice given to me for this March 7, 1988 hearing?
A: No. Hepburn deliberately made no attempt to give me any notice of the March 7th hearing, despite the knowledge and opportunity to do so.

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