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HomeMy WebLinkAbout00-06215 MARIE LOUISE ABRAM, * IN THE COURT OF COMMON PLEAS Plaintiff * CUMBERLAND COUNTY,PENNSYL VANIA * VS. * NO. 00-6215 * ADAM COMBS ABRAM, * CIVIL ACTION - LAW Defendant * IN DIVORCE CERTIFICATE OF SERVICE I, Misty D. Lehman, Legal Assistant to Edward J. Weintraub, Esquire, hereby certify that on September 12, 2000, I served a true and correct copy of an Custody Complaint filed on September 12, 2000, upon Sandy Meilton, Esquire, counsel for the Defendant, by depositing same, postage pre-paid, in the United States Mail, Harrisburg, Pennsylvania, addressed as follows: Sandra L. Meilton, Esquire P.O. Box 889 Harrisburg, PA 17108-0889 Date: Q-Id -aD 1i\ 1ft-At n'di ~aJ Misty D. ehman '''-",1"~~ I " . - - ~, " " I. I-: 'j l~,: H ;'1 ;'" ::;j I:~ l:; i'I! f~ ;'~! ~ii - l,~ ~, C""~ -c.:; '(~_ !' ., ~ ""/,'--- -- ",::',,\, S:>- ~::: l.:.. ~::; 5 c c r",,') .-, -' , .~_, "_" ~"W,"_,'llLt~~~fllt~~j;};O":>I!~it~!jijl'I~~~_ MARJE LOUISE ABRAM PLAINTIFF V. ADAM COMBS ABRAM DEFENDANT IN TIIE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA 00-6215 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, this 15th day of September , 2000, upon consideration ofthe attached Complaint, it is hereby directed that the parties and their respective counsel appear beforeMelissa P. Greevy, Esq. , the conciliator, at 214 Senate Avenue, Suite 105, Camp HiU, PA 17011 on the 18th day of October ,2000, at 1:00 p.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 defme 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: /sl 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 TOYOURATIORNEY AT ONCE. IFYOUDONOT 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 '~"- "'T '.' ,~ ~- ~~'. '.'" ..~iR:ll\'\;~,""""if...,,<g",,,;,>,f>-~~~'\il~M',"Tk^>"~'"'" "~ - ,I ' _ _ "-=,~"""",,-,'''--'''M,,,w~'$.'h''''''.;!;!1;.:i:,,);._"'''}'ti,,~~~LI~III.IIU- ,--...........~ . -- ,'" ''"r\ ......~~I'.\I...,\.'= ._1,\ \-'f,'L:r;,) ,I"'" \ "l...'. .0..'\,"'-t..nV ,...,._ TI-'- (:1'" pLln\ \Ji'- i \.,' -, ,_.il'.'- .II! 00 SEt' \ 9 PM 3: 1.3 CUM8tHI..,:.ND COUN1Y PENNSYLVAN\/\ tl/M tJ"/-tJtJ",,,J ~ 4' ~ 1-11 -tJt:/ ~ P4-~ ~ t# ~ f/f -c>>/~ /J1~ ~ 4~ "~~,- ~ . "_~~, 'n , ~, . -"'-'-" '" . - '-'- ---','" ,~ ,. ~ '~,-.- ."' ..,.. .'. ~" .~ , ,,-y-.'--''':> .-'",',:; MARIE LOUISE ABRAM, Plaintiff " IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 00- (.~/S (3".:[ ~ " " vs. " " ADAM COMBS ABRAM, Defendant " .CIVIL ACTION - LAW "0.--" e ORDER OF COURT AND NOW, this day of , 2000, upon consideration of the attached complaint it is hereby directed that the parties and their respective counsel appear before Esquire, the Conciliator, at , Pennsylvania, on the day of 2000 at o'clock, _.m., for a Pre-Hearing 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 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 entry of a temporary or permanent order. FOR 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. OFFICE OF THE COURT ADMINISTRATOR 1 COURTHOUSE SQUARE, 4TH FLOOR CARLISLE, PA 17013 (717) 240-6200 ~""'Y<1\j\\"","",,~.,.... ,,> MARIE LOUISE ABRAM, Plaintiff * IN THE COURT OF COMIVION PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. P-fJ _ ~ ';2/S {!WJ -r 1..-L4- vs. * * * * ADAM COMBS ABRAM, Defendant * CIVIL ACTION - LAW * n ..IE COMPLAINT FOR CUSTODY AND NOW, Plaintiff, Marie Louise Abram, by and through her attorney, Edward J. Weintraub, Esquire, files a Complaint For Custody against Defendant, Adam Combs Abram, and in support thereof, avers the following: 1. Plaintiff is Marie Louise Abram, Mother, who currently resides at 850 Walnut Lane, Carlisle, Pennsylvania. 2. Defendant is Adam Combs Abram, Father, who currently resides at 28 South Pitt Street, Carlisle, Pennsylvania. 3. Plaintiff seeks custody of the following child: NAME Present Address AGE Marie Claire Abram, 850 Walnut Lane, Carlisle, PA 7 4. The child was not born out of wedlock. 5. The child, Marie Claire Abram, is presently in the custody of Mother, Marie Louise Abram, who currently resides at 850 Walnut Lane, Carlisle, Pennsylvania 6. During the past five (5) years, the child, Marie Claire Abram, has resided with the following persons at the following addresses: 71"f<i1-W"\.,,,_.:l!9' _~ ".--1 Persons Address Mother and Father, 1095 Towne Lane, Charlottesville, VA Mother and Father, 415 Honker Drive, Florence, SC Mother and Father, 850 Walnut Lane, Carlisle, PA Mother, 850 Walnut Lane, Carlisle, PA Da1e 1/81-7/94 7/94[7/95 7/95+3/30/00 3/30/00-present 7. The Mother of the child is Marie Louise Abram, who currently resides at 850 Walnut Lane, Carlisle, Pennsylvania. 8. The Father of the child is Adam Combs Abram, who currently resides at 28 South Pitt Street, Carlisle, Pennsylvania. 9. The parties are married. 10. The relationship of Plaintiff to the child is that of Mother. Plaintiff currently resides with the following person: Person Relationship Marie Claire Abram Daughter 11. The relationship of Defendant to the child IS that of Father. Defendant currently resides with the following persons: Person Relationship 12. Plaintiff and Defendant have not participated as a Rarty or witness, or in another capacity, in other litigation concerning the custody of the child in this or another court. 13. Plaintiff and Defendant have no information of a custody proceeding concerning the child pending in a court of this Common~ealth. 14. Plaintiff and Defendant do not know of a person n<jlt a party to the -,~~:"""",- , d ~h__ , ~, \ - ~ proceedings who has physical custody of the child or claims to have custody or visitation rights with respect to the child. 15. The best interests and permanent welfare of the child, Marie Claire Abram, will be served by granting the relief requested, inter alia, because the Plaintiff Mother has been and should continue to be the child's primary caretaker. 16. Each parent whose parental rights to the child have not been terminated and the persons who have physical custody of the child have been named as parties to this action. All other persons, named below, who are known to have or claim a right to custody or visitation of the child will be given notice of the pendency of this action and the right to intervene. Name Address Basis of Claim NONE WHEREFORE, Plaintiff respectfully request that this Honorable Court enter an Order granting her shared legal custody and primary physical custody, with Defendant Father to have liberal partial physical custody. Dated: By: ".~ ward J. Weintraub'; Esquire 2650 North Third Street Harrisburg, PA 17110 (717) 238-2200 Attorney 10. #17441 ATTORNEY FOR PLAINTIFF .-,,,~ "~~~ __'T.O . VERI FICA TION I,Marie Louise Abram, hereby swear and affirm that the facts contained in the foregoing Complaint for Custody are true and correct and are made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. Date: q -I I-DO -(!/PM ( , ob-u", 'fJ.b(M Mane Louise Abram, Plaintiff ;'\O1!!'l!1l... I I , I , I ~ II i\ ','1' il 11, ; " i-~ ., {)q 6J R Vi 1 ~ f:. ~ h,~~ ~ t 9 ~g~ ~O'~h ~ r- ~ 3 " -Cl ill ;';l ,.iI ,~ ':1 ! :1 :1 ,-'j "I iJj ,!,,! ;q ~~J " :'~ "I ! -,I , " ;'1 0 ,--" C') e- el .::;--. " ') ~, 6'-1 l "I Z , " B , f (,? ." , r-:-: " -J'~~ ~ 0"'- );.. ( ~ ~,) . ,>- , , ,. f: -<~ 0::1 ~-" i "~,_~~,,._~~']~f'i'J';:"h'we~_ _.itIllliJJ~~~~;f!\lfJiH?:!<'~:r",'-,'-"i'3""""''''"-'i!T' '1:4",~'lGiI~'?"1."'''~~'~if(~!~l''''''''1~H~W;);<:'-'TII!,i-'''''''''''"l*,!~''!' . NQV 2 2 200~ 1 Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MARIE LOUISE ABRAM, vs. NO. 00-6215 Defendant CIVIL ACTION - LAW CUSTODY ADAM COMBS ABRAM, ORDER OF COURT AND NOW, this Z. ., f..l day of ~bV(' -.l.o , 2000, upon consideration of the attached Custody Conciliation Summary Report, it is hereby ordered and directed as follows: I. LEGAL CUSTODY 1. The parties, Marie Louise Abram and Adam Combs Abram, shall share legal custody of their minor Child, Marie Claire Abram, born June 20, 1993. All decisions affecting the Child's growth and development including, but not limited to: choice of camp, if any; choice of daycare provider; medical and dental treatment; psychotherapy, or like treatment; decisions relating to actual or potential litigation involving the Child, directly or as beneficiary, other than custody litigation; education, both secular and religious; scholastic, athletic pursuits and other extracurricular activities; shall be considered major decisions and shall be made by the parents jointly, after discussion and consultation with each other, and with a view toward obtaining and following harmonious policy in the Child's best interest. 2. Each party shall keep the other informed of the progress of the Child's education and social adjustments. Each party shall not impair the other party's right to share legal or physical custody of the Child. Each party shall give support to the other in the role as parent and to take into account the consensus of the other for the physical and emotional well-being of the Child. 3. While in the presence of the Child, neither parent shall make or permit any other person to make, any remarks or do anything which could in any way be construed as derogatory or uncomplimentary to the other parent. It shall be the expressed duty of each parent to uphold the other parent as the one whom the Child should respect and love. 4. It shall be the obligation of each parent to make the Child available to the other in accordance with the physical custody schedule and to encourage her to participate in the plan hereby agreed and ordered. 5. Each parent shall have the duty to notify the other of any event or activity that could reasonably be expected to be of significant concern to the other parent. -'~:JII!', ,_,.~. '_"__' ___,_c.~_ '~ii!lm~dll~'!!-"f.-i'l>'G.J,i6*>aW~-~" , ~~~m~ ' oJ-"'.""'IIii~ ~"';;CA"""~_,"""....._ _ :. " ,,",,~'.. :f: : r:iLEIJ,o.':FICE (J'" 'n ,~ (""'l" 'n'''O'r'RY -.... 1"' ! r,;"> t ,'J',..., f ;"hA iJ ~ Il"\.f I:' 00 NOli 30 PM I: 26 CUMBf.:RIA"JD COUNTY PfiNNSYLVAN/A " I I r ,. . 1 No. 00-6215 6. The parents shall communicate directly with one another concerning any parenting issue requiring consultation and agreement and regarding any proposed modifications to the physical custody schedule, which may from time to time become necessary, and shall specifically not use the Child as a messenger. Furthermore, neither parent shall discuss with the Child any proposed changes to the physical custody schedule, or any other issue requiring consultation and agreement prior to discussing the matter and reaching an agreement with the other parent. 7. With regard to any emergency decisions which must be made, the parent with whom the Child is physically residing at the time shall be permitted to make the decision necessitated by the emergency without consulting the other parent in advance. However, that parent shall inform the other of the emergency and consult with him/her as soon as possible. Day to day decisions of a routine nature shall be the responsibility of the parent having physical custody at the time. 8. Each parent shall be entitled to complete and full information from any doctor, dentist, teacher or authority and copies of any reports given to them as a parent. Such documents include, but are not limited to, medical reports, academic and school report cards, birth certificates, etc. Both parents may, and are encouraged to attend school conferences and activities. The Father's name shall be listed with the school as the alternative parent to be contacted in the event of an emergency and to be notified regarding school events. However, it will be Mother's primary responsibility to provide Father with copies of report cards and all notifications of major school events. 9. Neither parent shall schedule activities or appointments for the Child which would require their attendance or participation at said activity or appointment during a time when she is scheduled to be in the physical custody of the other parent without that parent's expressed prior approval. 10. The parties have aCknowledged that they have discussed and jointly made the following decisions: A. Carlisle Pediatric, Lynn Hoffman and Holly Bower, will continue to be the Child's pediatrician and accordingly, will provide medical treatment to the Child when necessary. B. The Child's legal name shall be Marie Claire Abram. She shall be known by this name for all purposes. The parties shall instruct their reSPective families and friends that the Child should not be referred to by any other name. 'cfT!1Il ~" '''''-.n____ _."','-,- !' r No. 00-6215 C. The parties shall expect the Child to attend college and post-high school training if she is a good student with the high probability of getting entrance and succeeding in college. The parties shall be both actively involved in the selection of an appropriate post-high school education for the Child and the choice of any college or institution shall be mutually agreed upon by Father, Mother and the Child taking into consideration the parents' then financial ability and economic circumstances, and the Child's needs, desires, talents and aptitudes for post-high school education. II. PHYSICAL CUSTODY 1. The parents shall share physical custody of the Child. Father shall have custody according to the following schedule: A. On alternate weeks, to begin November 10, 2000, from 5:00 p.m. Thursday until Monday morning when Father shall return the minor Child to school, or to the care of her Mother, B. Alternating Tuesday evenings from 5:30 p.m. until 7:30 p.m. to commence November 14, 2000, C. Alternating Thursday evenings and overnight from 5:00 p.m. until Friday morning when Father shall return the Child to the care of her Mother, or to school, unless otherwise agreed, To commence November 16, 2000, D. To commence November 20,2000, on alternate Mondays from 3:45 p.m. until Tuesday morning when Father shall return the Child to school or to the care of her Mother, unless otherwise agreed. 2. Father shall give a copy of his work schedule to Mother and shall provide Mother, at the time of the preceding custody exchange, of any days when he may be able to complete his work by noon and therefore be able to commence his 5:00 p.m. periods of custody at an earlier time. 3. Summer: The summer schedule shall follow the school year schedule with the following exceptions: A. Father's alternate Tuesday evening periods of custody shall be extended to the following Wednesday morning when the Child shall be returned to her Mother or daycare provider. '''rw.1!, _'_ ,~ -- ",-' ~ "_""":,~ - - ,.. -~ ,~ _,f" . i No. 00-6215 B. Each parent shall have the right to 3 blocks of 7 days Which would supercede the regular schedule, but not supercede not the holidays. Each parent shall elect one week each calendar month during the months of June, July and August, providing at least a 60-day notice to the other party as to their intended vacation times. In the event that both parents plan the same week for vacation, the person who first provides notice to the other shall have the chosen week. 4. Holidays: A. Thanksgiving: Thanksgiving 2000 and subsequent even-numbered years shall be with Father. Thanksgiving 2001 and subsequent odd-numbered years shall be with Mother. The Thanksgiving period of custody shall be from the Wednesday preceding Thanksgiving after work until the following Monday morning. B. Christmas and Spring Vacation: Shall be defined by the period of time from after school adjournment until the night before school resumes, and shall be shared equally by the parties. The first half of Christmas break 2000 and subsequent even-numbered years shall be with Mother. The second half of Christmas break 2000 and subsequent even-numbered years shall be with Father. The first half of Christmas break 2001 and subsequent odd-numbered years shall be with Father, and the second half of Christmas break and subsequent odd-numbered years shall be with Mother. The first half of spring break 2001 and subsequent odd- numbered years shall be with Father. The second half of spring break 2001 and subsequent odd-numbered years shall be with Mother. In even- numbered years, Father shall have the second half of spring break and Mother shall have the first half of spring break. C. At the end of the last night of Spring, Christmas and Thanksgiving breaks, the parents who had custody for the first half of the holiday period shall have the Child from 6:00 p.m. overnight, unless otherwise agreed by the parties. D. Memorial Day and Labor Day: The parties shall alternate Memorial Day and Labor Day. In 2001 and subsequent odd-numbered years, unless otherwise agreed, Father shall have Memorial Day from 5:00 p.m. Friday until 8:00 a.m. Tuesday. In 2001 and subsequent odd-numbered years, Mother shall have Labor Day from 5:00 p.m. Friday until 8:00 a.m. Tuesday. In even-numbered years, Mother shall have Memorial Day from 5:00 p.m. Friday until 8:00 a.m. Tuesday and Father shall have Labor Day from 5:00 p.m. Friday until 8:00 a.m. Tuesday. :" ~- -', -~-,~, ~ -.- > .". r' " t No. 00-6215 E. Independence Day: Independence Day celebration shall be alternated annually by the parties. The period of custody for this holiday shall be from July 3rd at 5:00 p.m. until July 5th at 8:00 a.m. In 2001 and subsequent odd-numbered years, Father shall have the Independence holiday. In 2002 and subsequent even-numbered years, Mother shall have the Independence holiday. F. Mother's Day/Father's Day: Mother's Day and Father's Day shall be observed from Sunday at 8:30 a.m. until Monday at 9:00 a.m. Mother shall have custody for Mother's Day and Father shall have custody for Father's Day. 5. The parties shall endeavor to provide each other with at least a 72-hour notice with regard to a change in the overnight schedule. Prior to engaging the services of a third party to provide childcare, each party shall be obligated to contact the other parent in the event that they are not able to exercise their period of custody in the event of work emergencies or for overnight custodial times. Additionally, this obligation to contact the other parent shall be extended to apply in the summer and including periods of vacation time. 6. Mass: During Father's periods of custody it shall be acceptable for the Mother to take the Child to Mass between 8:30 a.m. and 10:30 a.m. on Sundays unless Father has other plans and notifies Mother by 8:00 p.m. the preceding Saturday. 7. Special Family Events: Each party shall be entitled to a period of custody for such family events including, but not limited to, weddings, funerals, anniversaries and other such similar celebrations or family gatherings, upon reasonable notice to the other party. 8. Telephone Calls: The Child may contact either parent by telephone at any time. The parties may make one call each day to the Child at the other parent's home between 5:00 p.m. and 7:30 p.m. 9. Relocation: Either party may relocate upon a 90-day notice to the other party. 10. This Order is temporary in nature. The parties may modify this Order by mutual agreement. In the absence of mutual agreement, the Order shall control pending further Order of Court. ',.~ ., " . <""-..,,,,^ .~~~ -1-"-- "-'- . ! Plaintiff IN THE COURT OF COMMloN PLEAS OF CUMBERLAND COUNTY, PENNSYLVNAIA NO. 00-6215 MARIE LOUISE ABRAM, vs. Defendant CIVIL ACTION - LAW CUSTODY ADAM COMBS ABRAM, CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND 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 CURRENTL YI.IN CUSTODY OF Marie Claire Abram June 20, 1993 Father and Mother 2. A Conciliation Conference was held on November 13, 2000, withl the fOllowing individuals in attendance: the Mother, Marie Louise Abram, and her couns$l, Edward J. Weintraub, Esquire; the Father, Adam Combs Abram, and his counsel, Saridra L. Meilton, Esquire. 3. The parties reached an agreement in the form of an Order as attached. / /~I rr,;2.o7J() Date u~ Melissa Peel Greevy, Esquir Custody Conciliator '"",,,..,. , ~ ,. , ~',,,~. ' I' <' . No. 00-6215 BY THE COURT, J. Dis!: Sandra L. Meilton, Esquire, 111 N. Front Street, PO Box 889, Harrisburg, PA 17108-0889 Edward J. Weintraub, Esquire, 2650 N. Third Street, Harrisburg, PA 17110 L~ 1Y/~ 11'3~iOO p..~:!; ;'~'W'l'!,.,.,...,,,",_ '.." ., "," , ~ ~ ... MARIE LOUISE ABRAM, * IN THE COURT OF COMMON PLEAS Plaintiff * CUMBERLANDCOUNTY,lpENNSYLVANIA * Y5. * NO. 00-6215 * ADAM COMBS ABRAM, * CIVIL ACTION - LAW Defendant * IN DIVORCE CERTIFICATE OF SERVICE I, Misty D. Lehman, Legal Assistant to Edward J. Weintraub, Esquire, hereby certify that on March 23, 2001, I served a true and correct copy of Plaintiffs Responses to Defendant's Request for Production of Documents and Plaintiffs Answers to Defendant's Interrogatories upon Sandy Meilton, Esquire, counsel for the Defendant, by depositing same, postage pre-paid, in the United States Mail, Harrisburg, Permsylvania, addressed as follows: Sandra L. Meilton, Esquire P.O. Box 889 Harrisburg, P A 17108-0889 _M~lDty o. ~Lma~ Misty D. Lehman Date: 3-2.. -:y--<::>) ~ _c_, r" <. I ! j I i I~ " :1 ,j ! 1,1 ~! ,II ,r ". :!' ~'I 1."1 :',;;; N'''''' .~. , .. , ~_...' ~ ~:'" ':;-Cl ;-...) \1:) . ~o~ ~, = o ,.- ~, "'"0'-;- fitl'S=:' -7~";', ~!, :2?c, Zc 5;(::~ :.;; ::=t_ -< 'i :C~l ~ -~"-~ l)? '.i) c? l",~ ..~,~_,~f!!III, "~~, w~~*~'''-~~-'''''f~~i%'~W11l~!ljt~_'Hf'il[!;'"f;jf~f1\Wim!) ~_ [~ MARIE LOUISE ABRAM, * IN THE COURT QF COMMON PLEAS Plaintiff * CUMBERLANDCOUNTY;PENNSYLVANIA * Y5. * NO. 00-6215 * ADAM COMBS ABRAM, * CIVIL ACTION - LAW Defendant * IN DIVORCE CERTIFICATE OF SERVICE I, Misty D. Lehman, Legal Assistant to Edward J. Weintraub, Esquire, hereby certify that on September 7, 2001, I served a true and correct copy of the Petition to Modify Custody upon Sandy Meilton, Esquire, counsel for the Defendant, by depositing same, postage pre-paid, in the United States Mail, Harrisburg, Pennsylvania, addressed as follows: Sandra L. Meilton, Esquire P.O. Box 889 Harrisburg, P A 17108-0889 Date: C\~~r()\ , ~~ [). ~Y\DL-J MistYD. Lehman ,'"""1. "., '1-'- "c"-" - >'. I i Ii II Ii ,1 Ii 11 I: , I' _.,- "~H '" ,,,,,", 0,' ..,.~l.,"", "' ., - .,,~ g ~ -o'OJ ro r-r, Z:::C1 Ze '!l ~2~ !2,G )co 'bo "c: ~ .~~- CJ - U> ,"1"\ ~ - "'" ::;':. - t..'1 I'-' ~~"', ~~- '~ o '-(1 ~.? ~ ~,~ ~~ :~i~:\'~} .{~:~~ C)1\i --.{ ~6 :< j~",i$1<~~'~~~<I'~~~~i~I'l$lll!!l~_, ~-' NOV 2 0 2001 ~ " .. tr Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MARY LOUISE ABRAM, vs. NO. 00-6215 Defendant CIVIL ACTION - LAW CUSTODY ADAM COMBS ABRAM, ORDER OF COURT Oler, J. - AND NOW, this l'7 tl day of November, 2001, upon consideration of the attached Custody Conciliation Summary Report, it is hereby ordered and directed as follows: 1. The prior Order of November 29, 2000, shall remain in full force and effect pending further Order of Court, or an agreement of the parties. 2. The parties shall submit themselves and their minor Child to an independent custody evaluation to be performed by Dr. Arnold T. Shienvold. The parties shall sign all necessary releases and authorizations for the evaluator to obtain medical and psychological information pertaining to the parties and the child. Additionally, the parties shall extend their full cooperation in completing this evaluation in a timely fashion and in the scheduling of appointments. The cost of the evaluation shall be shared equally by the parties. 3. Following the receipt of the report from the custody evaluator, counsel for either party shall contact the Conciliator for the purpose of scheduling an additional Custody Conciliation Conference. BY THE COURT, .~ :;r. esley aOler, Dis!: Edward J. Weintraub, Esquire, 2650 N. Third Street, Harrisburg, PA 17110 Sandra L. Meilton, Esquire, PO Box 889, Harrisburg, PA 17108-0889 ~ ~ J/.:Jr.o/ C+. - '~-~ - .; '." -,' - " -. ,. . . .-r' ;.'"'- '--".-' _ r, ~ ;"' '"'~~Ili@l~!'I.~lo,_~"t;J~\~~~,~~IIiia/.~' "---^ -0', ""\ fILFD-~{)~:FJCE n:: --:C:i'KJTARY 01 'm\! 28 Pi"] 3: 05 CUM8ERLi~\jD COUNTY PENNSYLVANIA ~ ,.".,..",l;__>_~'~~'k.'\'-<"'''''''''''~~ ~~" ,"__'-_,'" _"_~, ""6""'-C->,~,_""""'>1''H''_, _~, 1'.'_.- M -. Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 00-6215 MARY LOUISE ABRAM, vs. Defendant CIVIL ACTION - LAW CUSTODY ADAM COMBS ABRAM, CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND 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 CUSTODY OF Marie Claire Abram June 20, 1993 Mother and Father 2. A Custody Conciliation Conference was held on November 2, 2001, with the following individuals in attendance: the Mother, Mary Louise Abram, and her counsel, Edward J. Weintraub, Esquire; the Father, Adam Combs Abram, and his counsel, Sandra L. Meilton, Esquire. The Conference was scheduled pursuant to Mother's Petition seeking to modify the present shared physical custody arrangement to an arrangement wherein she would have primary physical custody and Father would have custody for alternating weekends and some mid-week time. 3. The parties did not reach an agreement to modify the present Order. However, they did agree to participate in a custody evaluation with Dr. Shienvold and to return to the Custody Conciliation Conference following the receipt of of the custody evaluation. /0\310/ Date elissa Peel Greevy, Esquire Custody Conciliator -H>llJlW.", ,"". T :-,1 -~ . _,/;. L'-_ , e m,_ " MARIE LOUISE ABRAM, . IN THE COURT OF COMMON PLEAS Plaintiff . CUMBERLANDCOUNTY,PENNSYLVANIA . VS. . NO. 00-6215 . ADAM COMBS ABRAM, . CIVIL ACTION - LAW Defendant . IN DIVORCE CERTIFICATE OF SERVICE I, Misty D. Lehman, Legal Assistant to Edward 1. Weintraub, Esquire, hereby certify that on February 8, 2002, I served a true and correct copy of Plaintiffs Request for Production of Documents (Second Set) By Defendant upon Sandy Meilton, Esquire, counsel for the Defendant, by messenger delivered to: Sandra L. Meilton, Esquire III North Front Street Harrisburg, PA 17108-0889 Date: :;J -)f ~O& ~o. Misty D. Lefunan -_'-__O<.~,-!_,__,._"':"__'"'~'"_,;_~?,,,~'" ,_ ~",_,_",c.n___ ,_, . -.~., - & ,,, ~- ~"-' ,.~ I J,'...I , ;, 'I , ~.~ ""~ ~ , ~~~ ''''x _v; -~I ..c, '-~.'-' -<<' . .~~ ',,) ""-t~,_ ,,'''-",,-~~ _ ,,~-,,-" ~m";'l~J'ilIl~~~~ I o ,:;; <- -Ui-:'-l nlrj:-: Z' 05~~' ~~~. ==r~. >-r .:;:.>: :'=1 -<, -""'~ ~WJIl1I~," ,.. C) r"'0 .." r'l :0 " \'1 r.....:; (J~ ~_. _: --., .:;"':'-: ~~ -'-," MARY LOUISE ABRAM PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. 00-6215 CIVIL ACTION LAW ADAM COMBS ABRAM DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Tuesday, October 15, 2002 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Melissa P. Greevy, Esq. , the conciliator, at 301 Market Street, Lemoyue, PA 17043 on Tuesday, November 12, 2002 at 10:30 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 furuish auy and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: Isl Melissa P. Greevy. Esq~ ,.../ Custody Conciliator v 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 TillS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HA VB AN ATTORNEY 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, Pennsylvania 17013 Telephone (717) 249-3166 --~ , -~ p. !'~.Mi.!If}W.lf~;;';"":0~_~,cl;""'''''~_''bi.w;l!l;:ri'''''''!2.'~~'",:o.otm,,,;,j",k'''''~;:'',d'l~{,"",>ii:"'''''' '"~ ~: ~~~~~,"" ,,- ~~~.~_....... ~. , !',':}Yi\HY .....",. ?l 0", nr'.'r 'j' kl \1. ..... :.. ",j ,J '.. ~"'~' 'NIT'! CUh/;8t.r'i1..;~\ 'liL) ~/,:}>'J I PENNSY\..VJ\NI/\ )tJ .~CV It? /5'0,,) It) -15 .tJ;2 M.~~~4.~ '7l~~ Z4~ ~~-t;aIf~ """., ,'~-' ,.- . ~ '''~''-~''-~-''-''''-~'''"~ ,,- ,---, ,--,-'" ,,-"'" _ -,""","." ---.~" - ,'-'- - ---' ~- .'. - ,~,'^~' - ._,- v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 00-6215 MARY LOUISE ABRAM, Plaintiff ADAM COMBS ABRAM, Defendant CIVIL ACTION - LAW IN CUSTODY ORDER OF COURT AND NOW, upon consideration of the attached Petition, it is hereby directed that the parties and their respective counsel appear before , Custody Conference Officer, on the day of , 2002, at .m. at , 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, Children need not be present at the Conference unless their presence is requested by the Custody Conference Officer. Failure to appear at the Conference may provide grounds for the entry of a temporary or permanent Order. FOR THE COURT, Date of Order: By: Custody Conference Officer 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. The Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 Telephone No. (717) 249-3166 1\11:._, .,' ,< ., ~ v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO. 00-6215 MARY LOUISE ABRAM, Plaintiff ADAM COMBS ABRAM, Defendant : CIVIL ACTION - LAW : IN CUSTODY PETITION REQUESTING CUSTODY CONCILIATION CONFERENCE AND NOW comes the Defendant, Adam C. Abram, by and through his attorneys, Tucker Arensberg & Swartz, and petitions this Honorable Court as follows: 1, The parties are the parents of a minor daughter, Marie Claire Abram (hereinafter referred to as "Claire"). 2. An Order of Court was entered to the above term and number on November 29, 2000 with an attached Custody Conciliation Summary Report executed by the parties (copy attached hereto as Exhibit "A"). 3. As part of said Court Order, the parties share legal custody. 4. An issue has arisen with regard to Defendant's physical custody on Tuesday evenings from 5:30 p,m. until 7:30 p.m. 5, Since the inception of the Order, Plaintiff has provided transportation for the Tuesday visitations. Plaintiff has recently advised Defendant that she will no longer bring Claire to Carlisle for Defendant's Tuesday evening visit. 6. Defendant has offered a number of alternative approaches to handle this problem, including, but not limited to: (a) Defendant is willing to give up one of his alternating Tuesday evenings in return for Plaintiff's agreement to extend the other Tuesday to an overnight. (b) Alternatively, Defendant is willing to continue on the alternating Tuesday evening schedule and have Claire take the school bus from Harrisburg Academy to his home. Defendant would then share transportation to return Claire to Plaintiff's home at the end of his visit. 7. Defendant has consulted Plaintiff on this issue and the parties are unable to resolve the issue. 8. Defendant requests that Plaintiff allow Claire to continue with the alternating Tuesday evening schedule, WHEREFORE, Defendant requests the scheduling of a custody conciliation conference to resolve the issue of Claire's Tuesday evening visits with Defendant. Sandra L. Meilton, E uire TUCKER ARENSBERG & SWARTZ 111 North Front Street, P.O. Box 889 Harrisburg, PA 17108-0889 (717) 234-4121 ATTORNEYS FOR DEFENDANT -" -- , ~~ VERIFICATION I, the undersigned, Adam C. Abram, acknowledge that the facts stated in the foregoing document are true and correct to the best of my knowledge, infonnation and belief. I understand that any false statements herein are made subject to the penalties of 18 Pa. C.S.A. Section 4904 relating to unsworn falsification to authorities. t1(l~ Adam C. Abram Dated: /0-/-0.2...... I.~ r'- -, ,. ,-" Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MARIE LOUISE ABRAM, vs, NO. 00-6215 ADAM COMBS ABRAM, Defendant CIVIL ACTION - LAW CUSTODY ORDER OF COURT AND NOW, this 2.9+h day of JJO\~tl') ~f R ,2000, upon consideration of the attached Custody Conciliation Summary Report, it is hereby ordered and directed as follows: I. LEGAL CUSTODY 1. The parties, Marie Louise Abram and Adam Combs Abram, shall share legal custody of their minor Child, Marie Claire Abram, born Jl,me 20, 1993. All decisions affecting the Child's growth and development including, but not limited to: choice of camp, if any; choice of daycare provider; medical and dental treatment; psychotherapy, or like treatment; decisions relating to actual or potential litigation involving the Child, directly or as beneficiary, other than custody litigation; education, both secular and religious; scholastic, athletic pursuits and other extracurricular activities; shall be considered major decisions and shall be made by the parents jointly, after discussion and consultation with each other, and with a view toward obtaining and following harmonious policy in the Child's best interest. 2. Each party shall keep the other informed of the progress of the Child's education and social adjustments. Each party shall not impair the other party's right to share legal or physical custody of the Child. Each party shall give support to the other in the role as parent and to' take into account the consensus of the other for the physical and emotional well-being of the Child. 3. While in the presence of the Child, neither parent shall make or permit any other person to make, any remarks or do anything which could in any way be construed as derogatory or uncomplimentary to the other parent. It shall be the expressed duty of each parent to uphold the other parent as the one whom the Child should respect and love. 4. It shall be the obligation of each parent to make the Child available to the other in accordance with the physical custody schedule and to encourage her to participate in the plan hereby agreed and ordered. 5. Each parent shall have the duty to notify the other of any event or activity that could reasonably be expected to be of significant concern to the other parent. Exhibit "A" ~;~,- , '.', ,.., " - . --'-""--~~~ No. 00-6215 6, The parents shall communicate directly with one another concerning any parenting issue requiring consultation and agreement and regarding any proposed modifications to the physical custody schedule, which may from time to time become necessary, and shall specifically not use the Child as a messenger. Furthermore, neither parent shall discuss with the Child any proposed changes to the physical custody schedule, or any other issue requiring consultation and agreement prior to discussing the matter and reaching an agreement with the other parent. 7. With regard to any emergency decisions which must be made, the parent with whom the Child is physically residing at the time shall be permitted to make the decision necess.itated by the emergency without consulting the other parent in advance. However, that parent shall inform the other of the emergency and consult with him/her as soon as possible. Day to day decisions of a routine nature shall be the responsibility of the parent having physical custody at the time. 8. Each parent shall be entitled to complete and full information from any doctor, dentist, teacher or authority and copies of any reports given to them as a parent. Such documents include, but are not limited to, medical reports, academic and school report cards, birth certificates, etc. Both parents may, and are encouraged to attend school conferences and activities. The Father's name shall be listed with the school as the alternative parent to be contacted in the event of an emergency and to be notified regarding school events, However, it will be Mother's primary responsibility to provide Father with copies of report cards and all notifications of major school events. 9. Neither parent shall schedule activities or appointments for the Child which would require their attendance or participation at said activity or appointment during a time when she is scheduled to be in the physical custody of the other parent without that parent's expressed prior approval. 10, The parties have acknowledged that they have discussed and jointly made the following decisions: A. Carlisle Pediatric, Lynn Hoffman and Holly Bower, will continue to be the Child's pediatrician and accordingly, will provide medical treatment to the Child when necessary. B. The Child's legal name shall be Marie Claire Abram. She shall be known by this name for all purposes. The parties shall instruct their respective families and friends that the Child should not be referred to by any other name. = No. 00-6215 C. The parties shall expect the Child to attend college and post-high school training if she is a good student with the high probaQility of getting entrance and succeeding in college. The parties shall be both actively involved in the selection of an appropriate post-high school education for the Child and the choice of any college or institution shall be mutually agreed upon by Father, Mother and the Child taking into consideration the parents' then financial ability and economic circumstances, and the Child's needs, desires, talents and aptitudes for post-high school education. II. PHYSICAL CUSTODY 1. The parents shall share physical custody of the Child. Father shall have custody according to the following schedule: A. On alternate weeks, to begin November 10, 2000, fwm 5:00 p.m. Thursday until Monday morning when Father shall return the minor Child to school, or to the care of her Mother, B, Alternating Tuesday evenings from 5:30 p.m. until 7:30 p.m. to commence November 14, 2000, C. Alternating Thursday evenings and overnight from 5:00 p.m. until Friday morning when Father shall return the Child to the car~ of her Mother, or to school, unless otherwise agreed, To commence November 16, 2000, D. To commence November 20,2000, on alternate Mondays from 3:45 p.m. until Tuesday morning when Father shall return the Child to school or to the care of her Mother, unless otherwise agreed, 2. Father shall give a copy of his work schedule to Mother and shall provide Mother, at the time of the preceding custody exchange, of any days when he may be able to complete his work by noon and therefore be able to commence his 5:00 p.m. periods of custody at an earlier time, 3. Summer: The summer schedule shall follow the school year schedule with the following exceptions: A. Father's alternate Tuesday evening periods of custody shall be extended to the following Wednesday morning when the Child shall be returned to her Mother or daycare provider. 'T~Jl!f!il! ",~ ~- No. 00-6215 B. Each parent shall have the right to 3 blocks of 7 days which would supercede the regular schedule, but not supercede not the holidays. Each parent shall elect one week each calendar month during the months of June, July and August, providing at least a 60-day notice to the other party as to their intended vacation times, In the event that both paren,ts plan the same week for vacation, the person who first provides notice to the other shall have the chosen week. 4. Holidays: A. Thanksgiving: Thanksgiving 2000 and subsequent even-numbered years shall be with Father. Thanksgiving 2001 and subsequent odd-numbered years shall be with Mother. The Thanksgiving period of custody shall be from the Wednesday preceding Thanksgiving after work until the following Monday morning. B. Christmas and Spring Vacation: Shall be defined by the period of time from after school adjournment until the night before school resumes, and shall be shared equally by the parties. The first half of Christmas break 2000 and subsequent even-numbered years shall be with Mother. The second half of Christmas break 2000 and subsequent even~numbered years shall be with Father. The first half of Christmas break 2001 and subsequent odd-numbered years shall be with Father, and the second half of Christmas break and subsequent odd-numbered years shall be with Mother. The first half of spring break 2001 and subsequent odd- numbered years shall be with Father. The second half of spring break 2001 and subsequent odd-numbered years shall be with Mother. In even- numbered years, Father shall have the second half of spring break and Mother shall have the first half of spring break. C. At the end of the last night of Spring, Christmas .and Thanksgiving breaks, the parents who had custody for the first half of the holiday period shall have the Child from 6:00 p.m. overnight, unless otherwise agreed by the parties. D. Memorial Day and Labor Day: The parties shall alternate Memorial Day and Labor Day. In 2001 and subsequent odd-numbered years, unless otherwise agreed, Father shall have Memorial Day from 5:00 p.m. Friday until 8:00 a.m. Tuesday. In 2001 and subsequent odd-numbered years, Mother shall have Labor Day from 5:00 p.m. Friday until 8:00 a.m. Tuesday. In even-numbered years, Mother shall have Memorial Day from 5:00 p.m. Friday until 8:00 a.m. Tuesday and Father shall have Labor Day from 5:00 p.rn, Friday until 8:00 a.m. Tuesday. .1 '-- No. 00-6215 E. Independence Day: Independence Day celebration shall be alternated annually by the parties. The period of custody for this holiday shall be from July 3rd at 5:00 p,m. until July 5th at 8:00 a.m. In 2001 and subsequent odd-numbered years, Father shall have the Independence holiday, In 2002 and subsequent even-numbered years, Mother shall have the Independence holiday. F. Mother's Day/Father's Day: Mother's Day and Father's Day shall be observed from Sunday at 8:30 a.m. until Monday at 9:00 a.m. Mother shall have custody for Mother's Day and Father shall have custody for Father's Day. 5. The parties shall endeavor to provide each other with at least a 72-hour notice with regard to a change in the overnight schedule. Prior to engaging the services of a third party to provide childcare, each party shall be obligated to contact the other parent in the event that they are not able to exercise their period of custody in the event of work emergencies or for overnight custodial times. Additionally, this obligation to contact the other parent shall be extended to apply in the summer and including periods of vacation time, 6. Mass: During Father's periods of custody it shall be acceptable for the Mother to take the Child to Mass between 8:30 a.m. and 10:30 a.m. on Sundays unless Father has other plans and notifies Mother by 8:00 p.m. the preceding Saturday. 7. Soecial Family Events: Each party shall be entitled to a period of custody for such family events including, but not limited to, weddings, funerals, anniversaries and other such similar celebrations or family gatherings, upon reasonable notice to the other party, 8. Telephone Calls: The Child may contact either parent by telephone at any time. The parties may make one call each day to the Child at the other parent's home between 5:00 p.m. and 7:30 p.m. 9. Relocation: Either party may relocate upon a gO-day notice to the other party. 10. This Order is temporary in nature. The parties may modify this Order by mutual agreement. In the absence of mutual agreement, the Order shall control pending further Order of Court, -~-- '- , ~ No. 00-6215 BY THE COURT, .~ /5/ Dis!: Sandra L. Meilton, Esquire, 111 N. Front Street, PO Box 889, Harrisburg, PA 17108-0889 Edward J. Weintraub, Esquire, 2650 N. Third Street, Harrisburg, PA 17110 ;i~''!L , ... -." ~" ~~"'M "~ CERTIFICATE OF SERVICE AND NOW, this qfA day of t!)c;..<{()b-t/Z- , 2002, I, Gloria M. Rine, Paralegal to Sandra L. Meilton, Esquire, for the firm of Tucker Arensberg & Swartz, hereby certify that I have this day served a copy of the within document, by mailing same by first class mail, postage prepaid, addressed as follows: Edward J. Weintraub, Esquire 2650 North Third Street Harrisburg, PA 17110 ~.lkL Gloria M. Rine 53261,1 "'"'~ ~~ "'~ -""'-' ~ , -, - '"'~', r". ~. 4"~ ~ = .,>, ." l-J P ~ i Vt #- 0 . Cl 0 C) 0 C fv -n & ~ D <"' ,::> -~lr':-l ::;:1 rntTI C) -J ._,? .-< f "11~~~ ~ - ~;;: I"~'-'n r- (). F- t.} ,::> 7;~j c."J _. ~ r== ~-~() J- ~j;Cl ~D " .t;() 'c~~5 c: r,) (:5rn '"'(~ :..> 5;! ::;! :u 00 -< I-~,,~,Uli\ll MFml!liftI~ Jllllij~~il~~f~i'J%'i~_jl""''ll''f''';>W-.:;';l'I'!ffi1,!~n'lf@l.;P'''it,1~H'-'1'~IR'Ii'\~ilIliH!~;!I'!W!il:m~!ilJi!'ffljli~ ~'~ '" v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 00-6215 CIVIL ACTION - LAW : IN CUSTODY MARY LOUISE ABRAM, Plaintiff ADAM COMBS ABRAM, Defendant PRAECIPE PROTHONOTARY: Defendant herewith withdraws the Petition Requesting Custody Conciliation Conference filed by him on October 10, 2002. The custody conciliation conference set on said Petition for December 13, 2002 at 11:00 a.m. before Melissa P. Greevy, Custody Conciliator is hereby cancelled. ~b~.{~~ No. 32551 TUCKER ARENSBERG & SWARTZ P.O. Box 889 Harrisburg, PA 17108 (717) 234-4121 Dated: / I ~;)., /~O ;l, 1'-' "',:,'~':-:>""'-"-'~'-'---' - .__.___rj';_"'_~_' -'?->_:~_. -"-,,"'0-'" _ __,.~", ~.,~~_, . ~-_ r' CERTIFICATE OF SERVICE .-,nd AND NOW, this ^ day of D.t'''(,/h~ , 2002, I, Gloria M. Rine, Paralegal to Sandra L. Meilton, Esquire, for the firm of Tucker Arensberg & Swartz, hereby certify that I have this day served a copy of the within document, by mailing same by first class mail, postage prepaid, addressed as follows: Ii ! :1 " ~ ~ II fj u to 'I !~ ~ , ~ '1 " Ii 'i i~ I~ 'I Iii il !! "1 h ~! q L;! '. ~j " rl I:l I] 'I ::1 "l ::J i:i Edward J. Weintraub, Esquire 2650 North Third Street Harrisburg, PA 17110 Melissa P. Greevy, Custody Conciliator P.O. Box 109 Lemoyne, PA 17043 AL./h,L Gloria M, Rine 54863.1 [,j [-j i;1 "I' b- il..' 'I 1,1 !j'.' " i~, " i:.\ i4 ;, ~ " "1 j ::j ,I j,:j , [i " !l L ~, :,f,( '". '-".-, ...,,~~_,iO.'+_, ~,'-~~,+,,,--,-~- ~~v, ~', '--~T! ,- ,..-,-- "",,,,,~,,, ,-.-,-," ,--~".'~,~, ~ f~. . '"" "" "f.;___ d ~~t'"",' ,.Ul!lll!b<,.._"_ ."""' ;,-,.,- -., ~ -~-,,- " ~;""" ,.. .~''''''~='';'''. , ,-'-'-'",coc.-' . g c:> (') ", -T1 S =' ..... ~Q.: r11 J:-rl I r;~! n '-;1 f:'~ -.......-,'- :S:!f11: Z~-- , if> }::~ N "t ,'--, _r ..-': '~') I<C) :0" ~c1; ~O ~, ~2E5 - ,e'-t~n -L) Cf? 9. :Pc ~ ...! ~ -""",",- ,II~ V~ . MARIE LOUISE ABRAM, . IN THE COURT OF COMMON PLEAS Plaintiff . CUMBERLANDCOUNTY,IPENNSYLVANIA . VS. * NO. 00-6215 . ADAM COMBS ABRAM, . CIVIL ACTION - LAW Defendant . IN DIVORCE PRAECIPE FOR WITHDRAW OF APPEARANCE Please withdraw my appearance on behalf of Plaintiff, Marie Louise Abram, in the above captioned matter without prejudice. Date:~ i I Jerl~i r L. Frechette, Esquire for EdWard J. Weintraub, Esquire Weintraub & Associates PRAECIPE TO ENTER APPEARANCE Please enter my appearance on behalf of Plaintiff, Marie Louise Abram, in the above captioned matter. 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