Stephen D. Podd - Page 4

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               During 1989, Ms. Cohen frequently traveled to Montreal to              
          visit petitioner.  During 1990, Ms. Cohen's ex-husband, Bruce               
          Cohen, sued her for sole custody of their child, Gabrielle,                 
          alleging that Ms. Cohen's frequent trips out of the United States           
          resulted in her abandonment of Gabrielle.  The case was later               
          resolved, and Ms. Cohen retained joint custody of Gabrielle.                
          Afterwards, Ms. Cohen traveled to Montreal less frequently, and             
          petitioner increased the number of trips he made to Fort                    
          Lauderdale, Florida.                                                        
               During 1990, petitioner spent 160 days in Florida, 50 days             
          in South Carolina, and 35 days traveling through other parts of             
          the United States attending trade shows and spent 120 days in               
          Montreal.                                                                   
               On March 26, 1990, Powertex purchased mobile telephone                 
          service for petitioner's use at Ms. Cohen's apartment.                      
          Petitioner used a desk and a fax machine at Ms. Cohen's apartment           
          to conduct business while he was in Florida.  During May of 1990,           
          petitioner transported a boat owned by him and his brother,                 
          Stephen D. Podd, to Florida and docked it at the marina servicing           
          Ms. Cohen's apartment.  At that time, petitioner obtained an                
          insurance policy covering the boat and listed Ms. Cohen's                   
          apartment as his address.  While he was in Florida, petitioner              
          drove a car owned by Powertex.  On August 22, 1990, petitioner              
          obtained a Florida driver's license which identified his address            
          as that of Ms. Cohen's apartment.                                           



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