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HomeMy WebLinkAbout94-02374 I" MAY 26 199. d)c.- TRACI BOUCHBR, ) IN THB COURT OF COMMON Plaintiff ) PLBAB OF CUMBBRLAND ) COUNTY, PBNNSYLVANIA " vs. ) II ) NO. 94-2374 CIVIL TERM I, BOUCHBR, ) :: MARK D. Defendant ) CUSTODY 'i 'I ii 'I !. ORDER AND NOW, II conciliator's this ~(( r,1 day of / )/{'<-;f- , 1994, upon receipt of the report, it appearing that the parties agreed upon the terms and provisions of this temporary order which was dictated in their presence and approved by , them and their counsel, we hereby order as follows: 1. Primary physical and legal custody of the minor child, Bethanne Boucher, born November 13, 1985, shall continue in her mother, the Plaintiff, Traci Boucher. 2. Pending further order of this Court, the child's father, the Defendant, Mark D. Boucher, shall have the fOllowing periods of temporary custody: A. On the weekends of June 4 and June 18, 1994, at the mother's home at 6005 Bber1y Drive, Mechanicsburg, Pennsylvania, on Saturday from 11:00 a.m, until 6:00 p.m. and on Sunday from 9:00 a.m. until 3:00 p.m. The father shall not leave the mother's residence without the consent of the mother or the adult present at the residence, but the father shall have the child alone with him and the mother or the adult present at her residence shall not participate in the father's visitation with the child. B, Four days, or parts thereof, during the month of August which shall be Monday, August 8, 1994, from }:OO p.m. until 8:00 p.m. and Tuesday, August 9, 1994, from 1:00 p,m. until 6:00 p.m., and the same times again on Monday, } H'l Zl 8 23 ~H '9~ l.i fl'" .' ;"!lll" ~ . ~.. r ,I '1 '.\" ~ " 'Y -. , ,,' August 22, 1994, and Tuesday, August 23, 1994, unless the mother shall exercise her option as provided in SUb-paragraph C hereof. These visits will take place at the father's residence in New Jersey and the mother shall be responsible to deliver the child to the father's residence at 24 Park Avenue, Pomona, New Jersey, and pick the child up at that residence, at the specified times. C. In the event that the mother's schedule, or the child's schedule, make it more convenient for the father's visits during the month of August to take place over the weekends, at the mother's option, the father's periOdS in August shall fall on the weekends of August 6, 1994, and August 20. 1994. on Saturday from 11:00 a.m. until 6:00 p.m. and on Sunday from 9:00 a.m. until 3:00 p,m. As in SUb-paragraph B, the visits shall take place at the father's residence in New Jersey and the mother shall be responsible to transport the child to and from those periods, The choice between the dates in August shall be at the mother's sole option but she shall provide the father with written notice of the dates no later than July 20, 1994, and, in the event that she does not, the visits will take place on Monday and Tuesday evenings as provided in Sub-paragraph B hereof. 3. This is a temporary order only and will be addressed, expanded, modified, or otherwise amended as appropriate at a hearing to be held before the undersigned in Court Room No. ~ 01 the Cumberland County Court House in Carlisle, Pennsylvania, commencing at iJO i ,..'r {' If )}I/~( J , o'clock {c...m., on :.~ L< (,I rt '/.-. the .1 1994. The above schedule is made without c~ Iln day of prejUdice to the claims, defenses, and rights of either party, each of which shall be free to raise 2 whatever issues they choose at the said hearing. Each of the parties shall, through counsel, provide to the other party, a list of witnesses they intend to call at such ,hearing at least fifteen (15) days prior to the hearing, which list shall provide the "name, address, evening phone number of each witness and a brief description of the ',testimony they are expected to present. 4, We make no disposition of the father's claim, or potential claim, that the courts of New Jersey have jurisdiction in this matter. If either party wishes to raise ,or further litigate the issue of jurisdiction, however, they must file a petition or a : preliminary objection with us to do so no later than July 20, 1994. In the event either party raises such an issue, that will not postpone the hearing scheduled above and we will address that matter immediately prior to commencing the hearing. By the Court, ii ~ ! ;(l--' A /L J. James W. Abraham, Esquire , 116 Locust street Harrisburg, PA 17101 Attorney for Plaintiff / ,,~ fY\'<;.ooD.J .sJ~!JJ'I'f' ~\J ~,P. : Harry E. Franks, Jr. 1600 Atlantic Avenue Longport, NJ 08403 Attorney for Defendant sla 3 rn ~ t:l ~ .. 0 < .. !: ~ .. ~ = < :i .. ~ ~ ~ II: = ~ ~ ~ ~ 5 ... ... 1/1 >e >- ~ ;. .. 0 1/1 t:l l<l ~ " II: ;:l II: ci II: .< = ~ l<l 0 ;:: c; '" '" ~ = r>i 0 rn < z II: I<l ~ ;. Q " 0 ~ :r. ~ .. -< ... . . M ''I '1/' "30k . /-\1 ,..t) 1: ,yt ' O",....'~.,"." I: i: " j' ) IN THE COURT 01' COHHON . TRACI BOUCHER, Plaintiff ) I'LEAB 01' CUHBlIRI.ANIl ) COUNTY, l'ENNBYI,v AN I A vs, ) ) NO, 94-:13'14 CIVil, TllRH ,HARK D. BOUCHER, ) Defendant ) CUBTODY JUDGE PREVIOUSLY ASSIGNED: None CONCII.IATOR CONFERENCE BUHHARY REI'ORT. IN ACCORDANCE WITH CUHBERLAND COUNTY RULE OF CIVIl, PROCEIlURE 1915,3-0(bl, the undersigned Custody Conci Hator submils the following report: 1. The pertinent information concerning the child who Is the sUbject of this litigation is as follows: NAME CURRENTLY IN CU8TOllY OF BIRTIIDATE Bethanne Boucher 13 November Ig05 1'1 a I ntlf t/Mother 2. A Conciliation Conference was held on 23 May 1994 and the following individuals were present: the Plaintiff and her attorney, James W, Abraham, Esquire; the Defendant and her attorney, Harry E, Franks, Jr" Esquire, of 1600 Atlantic Avenue, 'Longport, NJ, 00403, 3, The father has apparently not seen the chi Id lor more lIlitn a year (the mother contends it was much longer but the father acknowledged It wan at leant 15 months or so). Although he has had telephone contact wilh the child, It appearn that his relationship with her is thin at best at the preGent time, 1~e mother Is concerned about gradually reintroducing the chi ld to the father no that she wi II not be traumatized by the experience, 4. Another problem is raised by a pending action in New Jersey. Attached is a copy of the latest order in that action, from which it appears that the court in New Jersey acted only because it felt the courts here had declined jurisdiction. 5, The parties were able to reach agreement for a temporary order of custody pending a hearing here or further litigation of the jurisdiction question. The attached order was dictated in their presence and approved by them and their counsel. 6. I suggest that a hearing be scheduled for sometime in late Angust. Frankly, I expect that. if the visits in June and August go well. the period of gradual reintroduction will have been satisfied and the parties can move on to a more traditional visitation schedule by agreement. 25 May 1994 S?:.~.~ Custody Conciliator .' . SUPERIOR COURT OF NEW JERSEY ATLANTIC COUNTY CHANCERY DIVISION-FAMILY PART KEKORANDUH OF DECISION ON HOTION WILLLUI C, TODD, III J.S.C. TO. Harry E. Franks, Esq. James W. Abraham, Esq. Dete. May 16, 1994 R. I lIouctu'r v. Iloucho r DoCket No, FM-ol-147-9IC " The Court renders the following duclslon after havIng carofully reviewed. Hoving papers filed . 4/20/94 Response/Crossmotion filod Cross-Response flledl Additional Responses. .1 Page I of 4 , ,. Boucher v. Boucher This Memorandum deals with plaintiff's Motion for enforcement of lhe terms of a Final Judgment of Divorce entered in 1991 dealing with his righl lO visitation with the parties' child. That application was unopposed. The Judgment of Divorce was entered April 5, 1991. The Judgment provides that defendant is to have custody of the parties' child, and thal plaintiff is to have specific vi5itation with that child lhroughout the year. The Judgment was spec! fica lly entered to,,! thollt prejudice" to plaint if f' s right to commence an action for custody, and apparently anticipates that additional "custody related proceedings" might occur in the State of Pennsylvania. It appears the child in question was residing in Pennsylvania at the time the Judgment was entered, and is still residing in that state, ,. Plaintiff indicates defendant has refused to comply "ith the terms of the Judgment dealing with visitation, that he has attempted to enforce the visitation provisions of the Judgment in the Pennsylvania courts, and that he was directed to proceed with applications for enforcement in this stale, Thi. court assumes the Pennsylvania courts have declined to entertain applications for enforcement of the terms of the Judgment on jurisdictional grounds. In the absence of any application to the contrary, this court is satisfied it should retain jurisdiction to deal with any applications related to the issues of custody an1 visitation, including plaintiff's current application for enforcement of the provisions of the Judgment of Divorce. The court specifically retains jurisdiction to deal with those issues generally. In that context, plaintiff's application for enforcement is granted, on the terms noted below. Plaintiff is to have the right to visitation with the parties' child two times each month, consistent with the terms of the Judgment of Divorce. Plaintiff may select the days on which his visitation is to be exercised in the following fashion. During those months when the child -2- 1.0. Boucher v. Boucher in question is attending school, plaintiff shall have the right to visitation two weekends each month, from 6.00 P.M. Friday to 6:00 P.M. Sunday. During those months when the child is not enrolled in school, plaintiff shall have one weekend visitation from 6.00 P.M. Friday to 6:00 P.M. Sunday, and one weekday visitation from 6:00 P.M. Wednesday to 6:00 P.M. Friday. Again, plaintiff is permitted to designate the specific days on which his visitation Is to be exercised, on the condition that he provide defendant with written notice of the days selected, in writing, by the first day of the calendar month in question, and at least seven days before any given visitation period, Plaintiff will have the obligation of picking up and returning the child for reach visi~ation period, In addition, plaintiff is to have the right to holiday visitation, consistent with the terms of the Judgment, In all even numbered years, including 1994, plaintiff is to have visitation for Thanksgiving and Easter, In all odd numbered years, beginning in 1995, plaintiff is to have visitation on the child's birthday and on Christmas. Each period of holiday visitation will be for 48 hours around the days noted, on specific dates to be designated by plaintiff, in accordance with the procedure set forth above. Plaintiff will be responsible for picking up and returning the child for the birthday visitation and Thanksgivingj(lsltation noted. Defendant will be responsible for delivering and picking up the child for the Easter visitation and Christmas visitation. Defendant Is specifically directed to strictly comply with the terms of the court's directions regarding visitation. In the event additional applications for enforcement are required, the court will consider ImposlllR appropriate sanctions and awarding attorneys fees and costs to plaintiff. -3- Boucher v. Boucher The court declines to award fees with respect to this application. Plaintiff's counsel is to submit an appropriate form of Order. ~~~ William C. Todd, III, J.S.C, ,. ~ -4_ TRACI BOUCHER, ) IN THE COURT OF COMMON P1ainti ff ) PLEAS OF CUMBERLAND ) COUNTY, PENNSYLVANIA vs. ) ) NO. 94-2374 CIVIL TERM MARK D. BOUCHER, ) Defendant ) CUSTODY ORDER AND NOW, this , 1994, upon receipt of the day of conciliator's report, it appearing that the parties agreed upon the terms and provisions of this temporary order which was dictated in their presence and approved by them and their counsel, we hereby order as follows: 1. Primary physical and legal custody of the minor child, Bethanne Boucher, born November 13, 1985, shall continue in her mother, the Plaintiff, Traci Boucher. 2. Pending further order of this Court, the child's father, the Defendant, Mark D. Boucher, shall have the following periods of temporary custody: A. On the weekends of June 4 and June 18, 1994, at the mother's home at 6005 Eberly Drive, Mechanicsburg, Pennsylvania, on Saturday from 11:00 a.m. until 6:00 p.m. and on Sunday from 9:00 a.m. until 3:00 p.m. The father shall not leave the mother's residence without the consent of the mother or the adult present at the residence, but the father shall have the child alone wi th him and the mother or the adult present at her residence shall not participate in the father's visitation with the child. B. Four days, or parts thereof, during the month of August which shall be Monday, August 8, 1994, from 1:00 p,m, until 8:00 p.m. and Tuesday, August 9, 1994, from 1:00 p.m. until 6:00 p.m., and the same times again on Monday, 1 August 22, 1994, and Tuesday, August 23, 1994, unless the mother shall exercise her option as provided in Sub-paragraph C hereof. These visits will take place at the father's residence in New Jersey and the mother shall be responsible to deliver the child to the father's residence at 24 Park Avenue, I, " Pomona, New Jersey, and pick the child up at that residence, at the specified times. C. In the event that the mother's schedule, or the child's schedule, make it more convenient for the father's visits during the month of August to take place over the weekends, at the mother's option, the father's periods in August shall fall on the weekends of August 6, 1994, and August 20, 1994, on Saturday from 11:00 a.m, until 6:00 p.m. and on Sunday from 9:00 a.m. Ii until 3:00 p.m. As in SUb-paragraph B, the visits shall take place at the father's residence in New Jersey and the mother shall be responsible to transport the child to and from those periods. The choice between the dates . in August shall be at the mother's sole option but she shall provide the father with written notice of the dates' no later than July 20, 1994, and, in the event that she does not, the visits will take place on Monday and Tuesday evenings as provided in Sub-paragraph B hereof. 3, This is a temporary order only and will be addressed, expanded, modified, or otherwise amended as appropriate at a hearing to be held before the undersigned in Court Room No. of the Cumberland County Court !louse in Carlisle, Pennsylvania, commencing at o'clock _.m" on , the day of 1994. The above schedule is made without prejudice to the claims, defenses, and rights of either party, each of which shall be free to raise 2 _.".~.. whatever issues they choose at the said hearing. Each of the parties shall, through ,counsel, provide to the other party, a list of witnesses they intend to call at such , ::hearing at least fifteen (15) days prior to the hearing, which list shall provide the :iname, address, evening phone number 01 each witness and a brief description of the , ;'testimony they are expected to present. 4. We make no disposition 01 the father's claim, or potential claim, that the in this matter. If either party wishes to raise or further litigate the issue of jurisdiction, however, they must file a petition or a preliminary objection with us to do so no later than July 20, 1994. In the event either party raises such an issue, that will not postpone the hearing scheduled above ! and we will address that matter immediately prior to commencing the hearing. I, By the Court, J. James W. Abraham, Esquire 116 Locust Street Harrisburg, PA 17101 Attorney for Plaintiff Harry E. Franks, Jr. 1600 Atlantic Avenue Longport, NJ 08403 Attorney for Defendant sla 3 TRACI BOUCHER Plaintiff IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNA. ~ NO. qL/ - ;1,379 (('VI I Tt. ril'l v. . . MARK D. BOUCHER Defendant CIVIL ACTION - LAW : IN CUSTODY ORDER OF COURT AND NOW, upon consideration of the attached Complaint, it is hereby directed that the p~r~ie. s,and their respective counsel, appear before <, ,~m"'" \ L, tl.",j" t \", , the Con~~lj.ator, on the ~"'>rddayof rvL':\ll ,1994, atJl.1:L.M., at the ( , located at 'i. Pennsylvania, for a Pre- Hearing Custody Conference. At suc 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 ~~1~ be present at the conference. Failure to appear at the conferenece may provide grounds for the entry of a temporary or permanent Order. FOR THE COURT: Date of Order: ,)-- b,t,1 ( ~l(<i'/ .J . A/4-1bol {Se( 1-.:72#/:/ / . 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. BY:t Court Administrator Cumberland County Courthouse, 4th Floor 1 Courthouse Square CarliSle, PA 17013 (717) 240-6200 HAY tJ 4 23 PH '9~ t ,CE . i ; -1, 'j. -'; r, ~ f, " 'j f i'I.", ' ; ",. TRACI BOUCHER IN THE COURT OF COMMON PLEAS Plaintiff . CUMBERLAND COUNTY, PENNA. . . . ql/. ;).374 v. . NO. . . . MARK D. BOUCHER CIVIL ACTION - LAW Defendant . IN CUSTODY . COMPLAINT FOR CUSTODY AND NOW, comes Plaintiff, Traci Boucher, by and through her attorney, James W. Abraham, Esquire, Abraham Law Offices, Harrisburg, Pennsylvania, and files the following Complaint: I. Plaintiff, Traci Boucher, is an adult individual who currently resides at 6005 Eberly Drive, Mechanicsburg, Cumberland County, Pennsylvania. 2. Defendant, Mark D. Boucher, is an adult individual, whose last known address 24 Park Avenue, Pomona, New Jersey. 3. Plaintiff and Defendant were married on June 20, 1985 and divorced on March I', 1991. The parties have one child, Bethanne Boucher, born November 13, 1985. 4. Plaintiff is the natural Mother of the child and Defendant is the natural Father of the child. 5. For the last five (5) years, the child has resided exclusively with Mother, in the state of Pennsylvania, at the following addresses, for the following periods of time: 6005 Eberly Dr, Mechanicsburg, PA 4355 Valley Road, Eno1a, PA 2812 N. 2nd st., Harrisburg, PA 5/93-5/94 4/91-4/93 11/89-4/91 6. Plaintiff has not participated as a party or witness, or in any other capacity in other litigation, concerning the custody of the child in this or any other court, except for the Final Judgment of Divorce of the parties, dated March 13, 1991, entered in New Jersey; which includes a custody provision. Said provision provides Mother with primary physical custody and Father with visitation for a 48 hour period, twice per month. A true and correct copy of the applicable provision, is attached hereto and made part hereof as Exhibit "A". 7. Plaintiff does not know of any person not a party to these proceedings who currently has physical custody of the child or who claims to have custody or visitation rights with respect to the child. 8. For the last five (5) separation in August, 1989, the Pennsylvania, exclusively with Mother. physical custody of the child as said interests of the child in that: A. Plaintiff has been the primary caretaker of the child for all of the child's life; B. Plaintiff can provide a more stable and secure family environment for the child; years, since the parties child has resided in Plaintiff seeks primary custody is in the best C. Plaintiff has had primary physical custody of the child since the parties' separation, and the child has prospered under said custody; D. Although Defendant has had court ordered visitaiton rights since March 13, 1991, since that time Defendant made only three (3) visits with the child during 1991: and has not made any attempts to see the child since then; nor has Defendant contacted the child by telephone or mail, on holidays or on the child's birthday; E. Plaintiff believes and therefore avers that Defendant since March 13, 1991, has been, and may currently, be invovled in drug and alcohol abuse; F. Plaintiff has never refused Defendant visitation rights unless Defendant has requested said visitation during times in which he had consumed and/or abused drugs and alcohol, or when it was otherwise unsafe for the child; 9. As a result of Defendant's history of drug and alcohol abuse, and possible current abuse of drugs and alcohol; and as a result of Defendant's arbitrary and deliberate neglect and abandonement of the child in failing to implement his visitation rights, Plaintiff submits that it is in the best interests of the child to indefinitely limit Defendant's visitation to three to four hours, of fully supervised visitation, in Mechanicsburg, Pennsylvania, two days per month. 10. Plaintiff further submits, that in view of Defendant's visitation record, that any failure of Defendant to implement his visitation rights as determined by the Court, should preclude Defendant from any future expansion of visitation rights. _.,...'_"'v."~ WHEREFORE, Plaintiff respectfully requests that the Court grant primary physical custody and legal custody of the child to Plaintiff, and provide Defendant with supervised visitation, in Mechanicsburg, Pennsylvania, three to four hours, two days per month. Respectfully submitted: James W. Abraham, Esq. Abraham Law Offices 116 Locust st. Harrisburg, PA 17101 (717) 232-7825 I.D. No. 46352 Attorney for Plaintiff DATE: 5/5/9':/ /''. II . ) ~ " // / /',' ':. .. J, 1 -"~",\",',.Ll1(V>> ( f LEI] ,/ .. I\PR 0 5 1991 Superior Court of WdW JI"SflY Gourily of Atlontlc ,CERTI. fA J:8UE L , ", CERTIFIED TO BE !11 if RUE copy WILSON, SUBIN cS. MAGUIRE, P,A. P, 0, BOX S"7 ATLANTIC CITY. NCW .JCRSey 00404 1"011) 347,730, ATTORNCYS rOR Plaintiff MARK D. BOUCHER VB. Defendant TRACI BOUCHER . - SUPERIOR COURT OF NEW JERSEY ATLANTIC COUNTY CHANCERY DIVISION FAMILY PART Docket No, FM-Ol-147-91C CIVIL ACTION FINAL JUDGMENT OF DIVORCE THIS MATTER having been heard on March 13, 1991, in the presence of Michelle D. Maguire, Esquire, attorney for plaintiff, Mark D. Boucher; and Edward P. Kozmor, Esquire, attorney for defendant, Traci Boucher; upon Complaint and Answer, and defendant having, withdrawn her Answer: and the Court having heard and considered the Complaint and proofs: and it appearing that plaintiff and defendant were married, and plaintiff having pleaded and proved a cause of action for divorce upon grounds of irreconcilable differences, and an eighteen (18) month separation having occurred, in such case made and provided; " II '" /:, /' and plaintiff having been a bona fide resident of the State for more than one year next preceding the commencement of this action; and jurisdiction having been acquired over defendant pursuant to the Rules governing the Court; and all stipulations ar~ illcorporllt~d ill this l'inal Judgment or Uivorce: and good cause having been shown; IT IS on thisSfh. day of ~ 1991, by the Superior Court of New Jersey, Chancery Division, ORDERED and ADJUDGED in said Court by virtue of the power and authority of this Court, and of the acts of the Legislature, in such case made and provided, does hereby ORDER and ADJUDGE that the said plaintiff, Mark D. Boucher, and defendant, Traci Boucher, be and are hereby divorced from the bond of matrimony, for the cause aforesaid, and the said parties, and each of them be freed and discharged from the obligations thereof and the marriage between the par~ies is hereby dissolved: and IT IS FURTHER ORDERED: 1. W~fe shall have custody of the minor child, Bethanne, without prejudice to Husband to commence an action for custody or further any custody related proceedings in the State of Pennsylvania which is the residence of the minor child. 2. Visitation shall proceed as follows: (a) Husband shall have visitation with Bethanne for a forty-eight (48) hour period, twice a month, Commencing on Friday, March 15, Husband will travel to the State of Pennsylvania, pick Bethanne up at -2- '. at 6:00 p.rn" on Wednesday evening. He shall return Bethanne / ' . .' .'. /' approximately 6:00 p,m" and return Bethanne to her mother at 6:00 p,m. on Sunday evening; (b) On Wednesday, March 27, Traci Boucher shall travel to the State of New Jersey and Husband shall 'be permitted visitation with the minor child, commencing to Wife's sister's residence in Ventnor at 6:00 p,m" on Friday evening, It is the intent and agreement between the parties that two visitations will take place per month, more specifically, every other week coinciding with the dates set forth above; (c) Husband and Wife shall alternate holiday visi tations with the child, those holidays being Easter, the child's birthday in November, Thanksgiving and Christmas. Wife shall commence said visitation schedule by keeping the child with her on Easter, 1991; Husband shall be permitted visitation with the child on her birthday; Wife shall be permitted Thanksgiving; and Husband shall be permitted Christmas. This schedule will' alternate each year. Said holiday visitation shall be f~r a forty-eight (48) hour period including the date of holiday. Husband and Wife shall also alternate transportation for these visitations. Thus, in that Husband shall have the child on the child's birthday, he will travel to the State of Pennsylvania to carry out this visitation: his next visitation ~lith the child being on Christmas, Wife shall travel to the State of New Jersey to allow this visitatiol1, This holiday visi tation schedule is in addition to the regu lar visi ta tion as set forth above. -3- " II ......... , . VERIFICATION I, ---- , /~4C / L{(\ uc I-I;~_X , the undersigned, hereby verify and confirm that I have reviewed the foregoing document and the statements therein are true and correct to the best of my knowledge, information and belief. I further understand that any false statements made herein are subject to the penalties of l8 Pa. c.S.A. Section 4904, relating to unsworn falsifications to authorities. DATE: 5)-1/;/ -4t!t/ -~Wtjfh4 _/ CERTIFICATE OF SERVICE I, James W. Abraham, Esquire, the undersigned, hereby certify that I have served a true and correct copy of the foregoing document, by certified mail, return receipt, upon the following person, on the date indicated below: Mark D. Boucher 24 Park Avenue Pomona, New Jersey DATE: S-S- - Cj t(- dj,.;CX<A~. , ,;"" .,;';:,; :;:,~,""" -.,','> ,:::~ <>[,:.;"j" " ),~;:c."(> ~$:>'Vi.L;~'i.;'rl'3lf~!~Jl.l'"",'}~'~f:'A'~' ~,;t~~.~f.?>if~~'t~#'?;\'r~." \ \ r Ilu J 8 2<l ~H '9~ . ~ ~ fie ( ,/~W~::T.\r,.,. "II" (','., ~. :,'.1,<; 1, ";',,, I Y . . .. I'~ '. .'" ~',' 1i i/D,50 5,OD jui. ~. .' I 'j ,.:..' , '15. 5"0 ,. " .,,,,-~,-,,~,---'~~- --- ._,---,_. -_.',....,..........'...._-_. .. d i .. ... " - . , . ..-,4 "0.-.-. 'fi' "_....~'.'....- ,,' "., , ' ." " ~, .,-- ,,;-., " -'..'-:::~' .. '''-'--'' , I', I , , , , I " I I I I I I I.' r __ ,\.... i, TRACI BOUCHER, I IN THE COURT OF COMMON PLEAS Plaintiff I CUMBERLAND COUNTY, PENNSYLVANIA I CIVIL ACTION v. I . NO. 94-2374 CIVIL TERM . MARK D. BOUCHER, . . Defendant I IN CUSTODY PRAECIPE TO WITHDRAW AND ENTER APPEARANCE TO THE PROTHONOTARY: Please withdraw my appearance as counsel for the Plaintiff in the above-captioned case and enter the appearance of Kathleen Carey Daley, Esquire. /. it:/ ~a~am, Esquire Attorney No. 46352 ABRAHAM LAW OFFICES 116 Locust Street Harrisburg, PA 17101 (717) 232-7825 ~i 'I~ C2 Kathleen Carey Daley, Attorney No. 30078 DALEY LAW OFFICES 1029 Scenery Drive Harrisburg, PA 17109 (717) 657-4795 ----. 96lv-lS9 <L~l) 60W V1N'VAlASNN3d '~nasl~WH 3AI~O ^~3N3::>S 6W~ S3::>I:l:lO MVI 3:>1:1:10 MVl A31VO Ilov 9 Lj 05 I d 19~ " ~,: ICF c: '., '\:"iF.'\:':,H,y t;l.J;'" I .: :,,:li:' G I, 'tTY F Ui ~. j I L ..~ Ij i:. I .