Technical Record-1.pdf

8/10/2019 Technical Record-1.pdf

1/125

(

M A R 1 7 2 0 14

TRANSCRIPT r t i : coRI )ONNO. 151759-3 APPELLATE NO.E2013-01528-COA-R3-CV

VOLUME I OF I

SUPPLEME NTAL # 2

APPEALED FROM

KNOX COUNTY CHANCER Y COURTAT KNOXVILLE, TENNESSEE

Michael W. Movers, CHANCELLOR

HOWARD G. HOGAN, CLERK and MASTERIN TI IL CASE OF

Pamela Moritz TulaPIainiiII/P.ppellant S.

Michael Peter Tula1)cf endaiit/Appcllec

TO THE

COURT OF APPEALSKNOXVILLE, TENNESSEE

JUDGMENT LOWER COURTPaniela A Modtz appeals the final judgment/order of the Chancery Court of Knox County lilC(I 011

May 31, 2013 to the Court of Appeals

Pamela A. Moritz, Pro Sc, 108 South Ann Street, Lancaster, PA.. 17602, (717)381-0329Phuntil I/Appcllaut

Kiniberlv R lavior, #018449, 135 S David Lane, Kiioxvihle, TN., 37922,(86J)693-8080lklcudaiit/Appcllcc

FILED THIS AY OF 0

COUwi LERK

NO. EPUTY CLERK

TRANSMITTED THIS AY OF 0


2/125

PAMELA MORTIZ (formerly Tulay)Plaintiff

Vs. o. 151759-3E2 Ol3-Cl528-COA-R3CV

MICHAEL PETER TULAYDefendant

INDEXSUPPLEMENTAL 1 2

DESCRIPTION

Administrative Order to RedirecL ChildSupport Payments

Alias Summons Issued

Answer

Answer

Cert fled Mail Receipt

Certified Mail Receipt

Certified Mail Receipt

Child Support Services

Child Sunporn Services

Flat

Injunction Issued and Executed

Issued Injunction

Issued Injunction

DATE AGE

O j , / O 2 J 2 C 6 2

0 3 / 0 / 2 0 1 C 7

05/20/2008 2

0 5 / 2 0 / 2 0 0 E 2

11/14 / / 2 0 0 1

11/ - 14 // 2001

04/22/2013 112

04/28,2006 :

ILO/01/'200 7 1

07/24/2008 5

08/13/2008 q

07/29/2008

07/24/2008

0 8 / 1 3 . / 2 0 0 8


3/125

Letter Filed

Letter Filed

Letter Filed - Motion for Default Judgment

Mediation Order

Modified Order/Notice to NiLlihoid Income forChild Support

Modified Order/NoLice to Njtoo..ricI .ncome forChild Support

Motion for Inclusion of Language ReflectingAttorney's Leon with Exhibits

Motion for Withdrawal of Counsel

Motion to Compel Discovery and for Sanctionsand Notice to Appear for Hearing

Motion to Permit Withdrawal of Counsel

Non Resident Notice

Notice

Notice of Appearance

Notice of Appearance - Faxed

Nonice of Atoorney's Lien

Notice of Hearing

Notice of Trial Calendar Conflict

Notice to Appear for Petition for Contempt,for Modification, and for Injunctive Relief

12/20/2S07 6

02/21/2013 7

01/31/2013 5

12/21/200/ 1 5

10/01 /1 2 0 0 7

09/26/2006 0

08/26/2002 9

05/05/2 CO 8 0

0 7 / 2 1 / 2 0 1 0 8

06/17/2008 0

05/17/2007 9

08/26/2002 4

04/04/2008

0 3 / 3 1 / 2 ' 0 0 8 7

06/12/2002

0 6 / 1 7 / 2 0 0 8 7

05/30/2008 5

0 7 / 1 9/1 2 0 1 0 1


4/125

Order

Order of the Court

Order Permittinq Withdrawal of Counsel

Order/Notice to Withhold Income for ChildSupport

PLoof of Publication of Notice in ReadingEagle

Report of the Mediator

Show Cause Order

Subpoena Issued

Subpoena Issued

Subpoena Issued

Summary of No--ices Prinred

Summary of Nor-ices Printed

Summary of Notices Printed

Surrmary.o I Not ces Printed

ummaru of No dc c Printed





Summary of Polices Printed

03/11/2014

06/07/2002 6

06/26/2008 8

04/28/2006 1

0 9 / ' 1 8 / 2 0 0 7 0 1

06/04/2002

10/ 1 8 / 2 0 0 2 8

03/20/2009 3

03 '5/20094

0 3 / ' 3 0 / 2 0 0 9 5

11/14 /2C 07 4

12/04/2007 a

01/07/2008 9

02 /05/2 0 0 8 c

03/31/20H 8 8

051/2- / 2 0 0 8 4

696 / 1 9 / / 2 0 0 8

06/26/2008 0

8 83/06/2009

0 4 / 2 0 / / 2 0 1 0


5/125






Summons Executed ecretary of State


Summons Executed - Secretary of State


Summons Issued and Executed







Supplemental Certificate of Appellate Record

Trial Notice

Trial Notice

Trial Notice

Trial Norice

05/10/2010

06/29/2010

00/16/2010

01/22/2013

01/31/2013

01/16/2008

0 5 / 1 6 / 2 0 1 3

05/16/2013

05/16/2013

07 3 1 / 2 0 0 1

10/18/2002

12/10/2010

03/28/2013

03/28/2013

03/28/2013

04/10/2013

0 2 / / 2 8 / 2 0 0 2

08/07/2002

10 1 6 / / 0 0 2

03/06/2003

8 9

9 0

9 2

9 4

9 6

50

1 ( 1 6

110

115

2 9

9 3

9 8

1 ) 7 0

102

1 0 4

120

S

18

2 6

2 7


6/125

Y COURT

PAMELA MORTIZ(forme rly TULAY) R 11 2014

Petitioner, OWA RD G'. HOGAN

vs. o. 151759-3

MICHAEL PETER TULAY,

Respondent.

ORDER

The Clerk of the Court has exhau stively com pared the contents of the Court's file

in the above-styled case. It appears that with the subm ission of the attached docu m ents,

the Court of Appeals will have every docu m ent w hich exists in our files. The Court finds

that no docum ents remain w ithin this file to further supplemen t the Appellate Record.

IT IS SO ORDER ED.

Entered this \ ay of

MICHAEL W. MOYERSCHANCELLOR

cc : am ela Moritz, Pro SeMichael Tulay, Pro Se


7/125

\ \5 IN THE CHANCERY COURT FOR KNOX COUNTY, TENNESSEE

PAMELA MORITZ TUL AY,

Plaintiff,

vs. o. 1I l-

EI)MICHAEL PETER TUL AY,

Defendant.

SUMMONS

To: MICHAEL PETER TULAY216 SUGARWO OD DRIVEKNOXVILLE, TN 37922

You are hereby sum moned and required to serve upon James B .. LaPevor, plaintiffsattorney, whose address is1 9 0 0First Tennessee Plaza, 800 S. Gay Street, Knoxville,TN3 7 9 2 9 ,an answer to the complaint herewith served upon you within3 0 days after service ofthis summons and complaint upon you, exclusive of the day of service. If you fail to do so,judgment by default can be taken against you for the relief demanded in the complaint.

Issued and tested this ay of 001.

\11Cerk >

Deputy Clerk -

NOTICE

To the defendant: MICHAEL PETER TULAY

Tennessee law provides a four thousand dollar ($4,000) personal property exem ptionfrom execu tion or seizure to satisfy a judgm ent. J.fajudgment should be entered against you inthis action and you wish to claim property as exem pt, you must file a written list, under oath,of the items you w ish to claim as exem pt with the clerk of the court. The fist may be filed atany time and m ay be change d by you thereafter as necessary, however, unless it is filed beforethe judgm ent becomes final, it will not be effective as to any execution or garnishme nt issuedprior to the filing of the list. Certain items are automatically exempt by law and d o not need tobe listed; these include item s of necessary wearing appare l for yourself and your family andtrunks or other receptacles necessary to contain such apparel, family portraits, thefamilyBible,and school books. Should any of these items be seized, you w ould have the right to recoverthem. If you do not understand your exem ption right or how to exercise it, you m ay wish toseek the counsel of a lawy er.

2


8/125

To the process server Defendant MICHAEL PETER TULAY can b e served at216SUGARW OOD DR IVE, KNOXVILLE, TENNESSEE, 37922.

I received this summ ons on the ay of ____ 20.__.

I hereby certify and return that onthe/ayof ,Z,9 001,1:

tnred this summons and a comp laint on d efendant MICHAEL PETER TULAY in the

liowing mann er.

[]failed to serve this sum mo ns within 30 days afts issuance b ecause:


9/125

Complete items 1, 2, and 0 completeitem 4 if Restricted Deliver, desired.

Print your name and address on the reverse

so that we can return the card to you. Attach this card to the back of the mailpiece,

or on the front if space permits.

1. Article Addressed to:

tWadj4Lrzrrc/ 1

A. Received by (Please Print

4t411&1 ( t )C. SianareA I

If YES,I.1

B. Date of DeliveryJ

t 11 u )t21DAgentW rAddressee I

? 11 Yes

13 No

3. S rvice TypeM.I D E xpress Mail

I Registered Return Receipt for Merchandise0 Insured Mail C.O.D.

4. Restricted Delivery? (Extra Fee) Yes

2. Article Number

(Transfer from service l 001 0320 0005 7874 1601

PS Form 3811,March 2001 omestic Return Receipt

(02595-01-M-142

4


10/125

I Complete items 1, 3. Also completeitem 4 if Restricted t ,ery is desired.

I Print your name and address on the reverse

so that we can return the card to you. Attach this card to the back of the mailpiece,

or on the front if space permits.

AddressedrUcle . to:

OgIto

O 4

P Received by (Please le-0 ) B. Date of Delivery

C . Signature

XAgent

D Addressee

D. Is delivery address different from item 1? 0 YesIf YES, enter delivery address below: No

3.a ic elype

44f9J C I Y K 1()J72 KgI stered Dnrcpt for Merchand ise13 Insured Mail

4. Restricted DeliveV4tra Fee) yes

2. Article Number(flsnsfer from service lab 001 0320 0005 787 618

PS Form 3811,March 2001 omestic Return Receipt 73 ., 02595-01M-14241

5


11/125

C1Y COURT TR AL N OTIFILE COPY

02/28/02

CHANCERY COURT CLERK400 MAIN STREET, CITY-COUNTY BLDGKNOXVILLE, TN 37902

TULAY PAMELA MORITZVs.

TULAY MICHAEL PETER

CASE NO: 01-151159 PLEASE BE ADVISED THEABOVE STYLED CAUSE IS SET FOR TRIALAT 9:30 ON 6TH DAY OF SEPTEMBER 2002

CHANCELLOR CHAN SHARON BELL

NOTICES SENT TO

AFEVOR JAMES R YNATT, WILLIAM A., JR.

6


12/125

1:21I N T H E C H A N C E RY C O U RT F O R K N O X C O U N T Y, T E N N E S S E E

PAMELA M. TULA.Y,

Plaintiff

V. Docket No. 1 517W- -3

M I C H A EL P E TE R T U L AY,

Defendant

R E P O RT O F THE MEDIATOR

Comes John K. Barber, Esqui re , pursuant to Rule 31 ,

Tennessee Supreme Court Rules, and would respectfully report as

follows:

1. Pursuant to the Order of th i s Cour t , the

parties participated in a mediation in my offices on May 10,

2002, and May 31, 2002. Present for the mediation were the

parties and their counsel.

2 . Al l par t ies negot iated in good fa i th , bu t the

resolution of this matter was unsuccessful by mediation.

3 . By agreement of the par t ies , the media t ion

fees shall be paid by the parties and need not be charged as

court costs.

Respectfully submitted this ay of June , 2002.

J O H N K . B A R BE RPryor, F lynn, Pr ies t & BarberTwo Cent re Square , Sui te 00625 Gay St ree tP. 0. ox 8 7 0Knoxville, Tennessee 37901( 8 6 5 ) 5 2 2 - 4 19 1

PRYOR, FLYNN

PRIEST & FIARBERATTORNEYS AT LAW

Suite 600

Two Centre SquareP.O. Box 670

Knoxvihe, TN 37901

e tor

1


13/125

PR'VR, FLYNN

PRIEST & HARBER

ATTORNEYS AT LAWSuite 600

Two Centre Square

P.O. Box 870

Knoxville, TN 37901

C E RT I F I C AT E O F S E RV I C E

The undersigned hereby cert if ies that an exact copyof this Report of the Mediator has been served upon thefollowing counsel of record by U.S. mail with sufficientpos tage thereon to ensure the de l ivery of s ame:

James R. LaFevorNickle & LaFevor1900 Fi rs t Tennessee P laza800 S . Gay St ree tK n o x v i l l e , Te n n e s s e e 3 7 9 2 9

Wil l iam A. Nynat t, J r.Sheppeard & Swanson6 1 6 W. R i l l Ave n u eP. 0 . B o x 2 1 4 9Knoxville, Tennessee 37901

This the ay of June , 2002.

J O B 2 / K . H A R B E R , M e d i a t o r

2

N


14/125

IN THE CHANCERY COUR T FOR KNOX COUNTY, TENNESSEE

PAMELA MORITZ TULAY,

Plaintiff,

VS.


Defendant

J

;: 0: 1 3

No. lVNoti of Entry Required

PERMANENT PARENTING PLAN

This Permanent Parenting Plan with respect to the parenting of their child(ren) ispresented by PAMELA MO RITZ TULAY, hereinafter referred to as Mother and byMICHAEL PETER TULAY, hereinafter referred to as Father.

This Permanent Parenting Plan has been reached by:[] Agreement [XI Mediation [J Other Alternative Dispute Resolution [ ] Court

Hearing on

I GENERAL INFORMATION

1.1 This parenting plan applies to the following children:Name irth Date rimary Residence for purposes of

the child custody jurisdiction (T.C.A.36.6-201) is with:

PETER MICHAEL TULAY 7129168_ X] Mother ]Fither

MONICA CLAIRE TULAY 0124189_ X] Mother ]FatherMARK KOLBE TULAY 5/07199 X] Mother ]Father

[]Mother ]Father

II. RESIDENTIAL SHARING SCHEDULE

These provisions set forth where the child(ren) shall reside each day of the year andwhat contact the child(ren) shall have with each parent.

2.1 Pro-School Schedule( ] There are no children of pre-schoo l age.( ] Prior to enrollment in school, the chlld(ren) shall primarily reside with[X] Mother [ I Father, except for the following days and times when thechild(ren) will reside with or be with the other parent:

From: _5:00 PM ON FRIDAY_ to _8:00 PM ON SUNDAY________day/time ay/time( ] every week [X] every other week []other________ _______ _______ ____and from: _5:00 PM ON FRIDAY to 10:00 AM ON SATURDAY alternate weekends

day/time ay/time(]every week [xl every other week [X] other the pro-school child will go withhis older brother and sister.

2.2 School ScheduleUpon enrollment in school, the child(ren) shall primarily reside with (X] Mother[ ] Father, except for the following days and times when the child(ren) will residewith or be with the other parent:From: _FRIDAY AT 5:00 PM SUNDAY AT 8:00 PM________

day/time ay/time

9


15/125

4 0 0

( I every week X Ievery other week (] other__________________________and from: _FRIDAY AT 5:00 PM o _SATURDAY AT 10:00 AM onalternate weekends

day/time ay/time(]every week [X] every other week []other_________________________

] The school schedule will start when each child begins:(]kindergarten (]first grade (X] other children have been and are home

schooled by Pamela Tulay, so this schedule will be started now.

2.3 Schedule for Winter/Christmas Vacation (if applicable)The child(ren) shall reside with the [X] Mother [ ] Father during winter vacationexcept for the following days and times when the child(ren) will reside with or bewith the other parent:_FROM 10:00 AM. ON CHRISTMAS DAY (DECEMBER 25Th)TO 7:00 PM ON JANUARY 1 3 TEVERY YEAR.

2.4 Schedule for Spring VacationThe child(ren) shall reside with the (X] Mother ( ] Father during spring vacationexcept for the following days and times when the child(ren) will reside with or bewith the other parent:_FROM FRIDAY AT 5:00 PM ON MEMORIAL DAY WEEKENDTO 7:00 PM THE FOLLOWING MONDAY EVERY YEAR

2.5 Summer ScheduleUpon completion of the school year, the child(ren) shall reside with (XJ Mother()Father, except for the following days and times when the child(ren) will residewith or be with the other parent:[X] Same as school year schedule (]Other____________________________

2.6 Vacation with Parents

(I Does not apply.(X] Schedule for vacation with parents as follows: CHILDREN WILL RESIDEWITH FATHER FOR TWO (2) SEVEN DAY PERIODS AS DETERMINED PRIOR TOMAY 1. MOTHER SHALL ALSO HAVE THE RIGHT FOR A THREE WEEK PERIODOF EXCLUSIVE TIME FOR SUMMER VACATION TO BE CHOSEN BY HER.

2.7 Schedule for Holidays and Other Special OccasionsThe residential schedule for the child(ren) for the Holidays listed below is asfollows: (specify year)

With Mother(even, odd or every)

THANKSGIVING .EVEN

MOTHER'S DAY .EVERYFATHER'S DAY

With Father(even, odd or every)__ODD_______(THANKSGMNG EVE FROM5:00 PM TO THURSDAY AT7:00 PM)

EVERY

(] Holidays which fall on a Friday or a Monday shall include Saturday andSunday. [JOther

2.8 Priorities Under the Residential ScheduleDefined Holiday, vacation and other periods above override the generalrotation of shared parenting.

2.911esttictions

(XJ Does not apply because there are no limiting factors in Section VI below.

1 0


16/125

[] The [ ] Father's [ ] Mother's residential time with the child(ren) shall belimited because there are limiting factors in Section VI. The followingrestrictions shall apply w hen the child(ren) spend time with this parent:

] There are limiting factors in Section VI, but there are no restrictions onFather's ( ] Mother's residential time with the children for the following

reasons:

2.10 Transportation Arrangements

Transportation arrangeme nts for the child(ren), other than costs,between parents shall be as follows: ALL TRANSPORTATION WILL BEBY THE FATHER EXCEPT IN RARE INSTANCES AND WHEN OTHERARRANG EMENTS ARE M ADE 48 HOURS PRIOR TO VISITATION.

2.11 Designation of CustodianThe child(ren) named in this parenting plan are sched uled to reside themajority of the time with the [X] Mother []Father. This parent is designatedthe custodian of the child(ren) solely for purposes o f all other state and federalstatutes which require a designation or determination of custody. Thisdesignation shall not affect either parent's rights and responsibilities underthis parenting plan.

2.12 Other

Ill. DECISION MAKING

3.1 DAY TODAY DECISIONSEach p arent shall make decisions regarding the day-to-day care and co ntrol ofeach child while the child is residing with that parent. Regardless of theallocation of decision making in this parenting plan, either parent may makeemergency decisions affecting the health or safety of the children.

3.2 MAJOR DECISIONS

Major decisions regarding each child shall be made as follows:Education decisions 1 mother [] father X] jointNon-emergency health care Xj mother []father ]jointReligious upbringing ]mother []father X] joint

mother (J father ]joint(Jmother []father ]joint

mother [] father ]jointIn case the parties are unable to agree on joint decisions, mother's

decision will take precedentbecause mother has primaryresponsibility of the day to daycare and these a re part of herprimary duties.

3.3 Restrictions in Decision-Making(X] Does not apply because there are no limiting factors in Section VI.(] Sole decision-making shall be decreed to the [ ] Mother [3 Father for the

11


17/125

following reasons:

[]A limitation on the other parent's decision-making authority is mandated byT.C.A.36-6-406 . (See Section VI.)(] Both parents are opposed to m utual decision-making(J One parent is opposed to mutual decision-making, and such opposition isreasonably based on the following criteria:

( ] The existence of a limitation under T.C.A. 36-6406;[ ] The history of participation of each parent in decision-making in

each of the areas in T.C.A. 36-6404;

(] The parent's ability and desire to cooperate w ith one another indecision-making in each of the areas of T.C.A. 36-6404; and

[ ] The parents' geographic proximity to one another, to the extent thatit affects their ability to make timely m utual decisions.(] There are limiting factors In Section VI, but there are no restrictions onmutual decision-making for the following reasons:_______________________

IV. DISPUTE RESOLUTION4.1 Dispute Resolution(] No dispute resolution process, except court action, shall be ordered because[]a limiting factor under T.C.A. 36-6406 applies or (]

[X] Disputes between the parties, other than child support disputes, shall besubmitted to:

(] Counseling by or.(X] Mediation by DR. JOHN KA NDILAKIS or,(] Arbitration by____________________________________

4.2 CostsThe cost of the Section 4.1 process shall be allocated between the parties asfollows:

[X] _____ _ Mother Father(X] Based on eac h party's proportional share of income as defined

under the child support guidelines.(] As determined in the dispute resolution process.

4.3. Notification[X] The counseling, mediation or arbitration process shall be commenced by

notifying the other party by:(] Mail []Certified Mall [X] Other TELEPHONE, FOLLOWED BYMAIL, IF NECESSARY______________

4.4 Process(X] In the dispute resolution process:

(a.) Preference shall be given to carrying out this Parenting Plan.(b.) Unless an emergen cy exists, the parents shall use the designated

process to resolve disputes relating to Implementation of the plan,except those related to financial support.

(c.) A written record shall be prepared of any agreem ent reached incounseling or mediation and of each arb itration award and shall beprovided to each party.

(d.) If the court finds that a parent has u sed or frustrated the disputeresolution process without good reason , the court shall awardattorney's fees and financial sanctions to the other parent

(e.) The parties have the right to review from the dispute resolution processto the Chancery Court.

12


18/125

V. CHILD SUPPORT

5.1 Financial Support[X] The (] Mother (XJ Father will pay child support in the amount of $3,900 permonth or $1,800.00 per BI-WEEKLY PAY PERIOD beginning _NOVEMBER 1, 2001.FATHER WILL PAY CHILD SUPPORT BY PERSONAL CHECK UNTIL PAYROLL 0 n

S ( 1 AJDIRECT DEPOSIT TO SUNTRUST BANK, ACCOUNT NO. 547036183 TAKESEFFECT.[X] The payer of child support shall make the payments set forth above directlyto the other parent by mail or delivery at other's home with children.

[] The payer of child support shall make the payments set forth above by wageassignment together with a 5% fee for a total of $______ per____________beginning(X] The payer of child support and the payer's attorney, if any, affirm that thisamount conforms to the Tennessee Child Support Guidelines.(] The payer of child support and the payer's attorney, if any, affirm that thisamount of child support does not conform to the Tennessee Child SupportGuidelines, but it is in the best interest of the child(ren) because

and should nevertheless be approved by the Court because

The amount payable under the Guidelines would be: $_________________[X] A wage assignment shall issue by separate order presented together with

the filing of this plan to SEQUOIA CONSULTING GROUP, the employer of thepayer of child support, whose address is 111 WASHINGTON STREET,

PLAINSV1LLE, MA 02762. The payer's social security number is 167-44-5376.(XJ Other provisions for financial support: FATHER WILL PAY SUPPORT ON

ANY ADDITIONAL INCOME AT 41% OF THE AFTER TAX SUMS AS REQUIRED BYTENNESSEE LAW.

[X] The parties affirmatively acknowledge that no action by either or both ofthem will be effective to reduce child support after the due date of each payment.The parties further understand that Court approval must be obtained before childsupport can be reduced or modified, unless such payments are automaticallyreduced or terminated under the terms of this parenting plan.

5.2 Tax Deduction

] The ( ] Mother (X] Father will receive the tax deduction for the child(ren).Each party shall provide to the other, by or before April 15 of every year, a copy of

their respective W-2 form or a copy of the first TWO pages of their tax return.(X] Other provisions regarding tax deduction:

The obligor [FATHER] shall report annually on the _30TH S Tday of _APRIL . .to the obligee [MOTHER], and the Department of Human Services or its contractorin Title IV-D Cases, on a form provided by the Court, the obligor's income asdefined by the child support guidelines and related provisions contained in Title36, Chapter 5.

5.3 Health Insurance[ X ] The (1 Mother [X] Father shall maintain medical/hospital insurance on theminor child(ren) and he shall provide proof of continuing coverage upon demand,but in any event annually.(X] Uncovered medicals, including deductibles, if any, will be

(X] borne by [] Mother [X] Father[ ] divided equally by the parties

] shared as follows:______________________________________

1 3


19/125

5.4 Life InsuranceThe (1 Mother (X] Father shall insure his own life in the minimum amount of$100,000.00, whole or term, which may not decrease in face am ount during theminority of any child. The policy shall name the minor child(ren) as primarybeneficiaries of the coverage required by the Court. The choice of the secondarybeneficiary(ies) is up to the policy owner(s).

[ X ] Other provisions regarding life insurance: FATHER'S SAVINGS WILL BENOTED AS PAY ON DEATH ACCOUNTS FOR THE CHILDREN IN EQUAL SHARESUNTIL HE REMARRIES.

5.5 Dental/Orthodontic careThe [ ] Mother [ ] Father will maintain L ] dental(] and orthodontic insuranceon the minor child(ren). Uncovered expenses will be borne by () Mother(X] Father

(1divided equally by the parties.

[X] Other provisions for dental/orthodontic care: NO DENTAL INSURANCEHAS BEEN MAINTAINED IN THE PAST; HOWEVER, IF FATHER CHOOSES, HEMAY COVER THE CHILDREN FOR DENTALJORTHODONTIC CARE AT HISEXPENSE TO REDUCE THE COST TO HIMSELF.

Vi. BASIS FOR RESTRICTION

6.1 Restrictions due to Parental Conduct (T.C.A. 36.6-406)[X] Does not applyI Mutual decision-making and designation of a dispute resolution process otherthan court action shall NOT be required because (] Mother (] Fatherhas engaged in:(] Willful abandonment that continues for an extended period of time orsubstantial refusal to perform parenting responsibilities.

(] Physical, sexual, or a pattern of emotional ab use of a child or o f anotherperson living with that child.[J A history of acts of domestic violence as defined in T.C.A. 36-3-601 or anassault or sexual assault which caused serious bodily injury or the fear of suchinjury.(] Other.

VII. STANDARD PARENTING ORDERS

Pursuant to T.C.A. 36-6-101 both parents are entitled to the followingrights:

1. Unimpeded telephone conversations with the child(ren) at least

twice each week at reasonable times and for a reasonableduration;2. Sending mail to the child(ren) which the other parent will not open

and will not censor;3. Receiving notice and relevant information as soon as practical

(but not more than 24 hours) in the event of hospitalization, majorillness, or death of the child(ren);

4. Receiving, directly from the school, copies of the child(ren)'sreport cards, attendance records, teachers' names, classschedules, standardized test scores, and other records which arecustomarily made available to parents. A written request must bemade to the school with a current mailing address and paymentmust be m ade for the reasonable cost of duplicating and mailingthese records;

S. eceiving, directly from the child(ren)'s physician and other healthcare providers, copies of the child(ren)'s medical records. Awritten request must be made to the health care provider with acurrent mailing address and payment must be made for the

14


20/125

reasonable cost of duplicating and mailing these records;S. To be free of derogatory remarks made about one parent and his

or her family by the other parent to the child(ren) or in thechild(ren)'s presence.

7. To be given at least 48 hours notice, whenever possible, of allextracurricular activities and the opportunity to participate orobserve, including but not limited to, the following: (a) schoolactivities; (b)church activities; and C) other activities as to whichparental participation or observation would be appropriate;

8. To receive from the other parent, in the event the other parentleaves the state with the minor child for more than two days, anitinerary including telephone numbers for use in the event of anemergency; and,

9. Of access and participation in education, including the right ofaccess to the minor child for lunch and other activities, on thesame basis that is provided to all parents, provided theparticipation or access is reasonable and does not interfere withday-to-day operations or with the child's educational performance.

VIII. OTHER PROVISIONS

8.1 ViolationsViolations of residential provisions of this order with actual knowledge of itsterms are punishable by contempt of court and may be a criminal offense underT.C.A. 39-13-306, Tennessee custodial interference statute. Violation of thisOrder may subject a person to arrest.

8.2 Good Faith

When mutual decision-making is designated but cannot be achieved, the partiesshall make a good faith effort to resolve the issue through the dispute resolutionprocess, as detailed above in Section IV.

8.3 Binding EffectIf one parent fails to comply with a provision of this plan, the other parent'sobligations under this plan are not affected.

8.4 Other ProvisionsX] There are no other provisions.

I There are the following other provisions:__________________________

IX. DECLARATION FOR AGREED PARENTING PLAN

(] Does not apply[X] We agree to be bour)d by the foregoing Permanent Parenting Plan andundersnd that it 11 bco e a Court order when acted upon by the Court.

(/ 32

MORITZ TULAY // ate and place'of signature'

Sworn to and subscribed before me this ( ay of 001.

\CLC ?m y Commission Expires: 4 _oS

J OTARY PUBLIC

15


21/125

Ml HALPETERTULAYHj/3 J o t tp.v ifr,ft -

Da te and place of signature

Sworn to and subscribed before me this 13 day of _ 001.

Th y Commission Expires: LA o

U NOTARY PUBLIC

O RDER O F THE CO URT

It is ORDERED, ADJUDGED AND DECREED that the Parenting Plan set forthabove is adopted and approved as an order o f this court.

Dated: ____ udge: M . 7 7 9

Presented by Counsel: UN 7 2002

51OWARD G. hOGAN

S gnature PR # Signature PR #

Name JamesR.LaFevor ameAddress 800 S.Gay Street Ste. 1900 ddress

Knoxville, TN 37929-1900Phone (865)637-6258 hone

Address of Mother ddress of Father

PAMELA MORITZ TULAY.

_9423 YUMA DRIVE__________

_KNOXVILLE, TN 37931

Dates of Tenn. Code Ann. 36-6.408parenting classes attended:

_MICHAEL PETER TULAY.

_8705 PERCY WAY

_KNOXVILLE, TN 37923

Dates of Tenn. Code Ann. 36-6-408parenting classes attended:

Mothers certificate of successfulcompletion of parenting classeswas filed with ths Clerk's officeon the day of . 2 0 .

Father's certificate of successfulcompletion of parenting classeswas filed with this Clerk's office onthe ________ day of 20_:

Deputy Clerk eputy Clerk

CERTIFICATEI, Rm.e S. o ;n S.c .o; oLtiSt tSc,S I hc0 IJtra

[If applicable] Mediation servic es p ro vided by: John KandilakisChiId & Clinical li

Psychology ,135 Fox Road Knoxville TN Tel (865) 694-8792pa:tioc 0; '11 elI ottSn; 00 or; w Sore not approved

OOL,0, by pia.yn;oa;;o is ISO U.S. 15a1, postage p;tpoiii 51115

_-tf_ 4 J_I 6Q8

CIek & SeatS rshascoi,4ry\

-- eputj den 1 6


22/125

IN TUE CHANCERY COURT FOR K NOX COUNTY, TENNESSEE

PAMELA MOR1TZ TTJLAY,

Plaintiffi, -.)

vs. o. 15 59-3

) oti of E ntry RequiredMICHAEL PETER TULAY,

Defendant.

NOTICE OF ATTORNEY'S LIEN

Comes James R. LaFevor, attorney of Nickle and LaFevor, -and hereby gives notice of a

lien upon the plaintiffs right of action in this cause pursuant to Tennessee Code Annotated

23-2-102, and requests that this matter be set for a hearing prior to disbursement of any fends

whether pursuant to settlement or judgment.

pectfiilly submitted,

James R. LaForNICKLE and LAFEVOR

1900 First Tennessee Plaza800 S. Gay StreetKnoxville, TN 37929(865) 637-6258(865) 637-8476 FAX

CERTIFICATE OF SERVICE

This is to certify that a true and exact copy of the foregoing Notice of Attorney's Lienhas been placed in the U. S. Mail for delivery to:

Diane M. MesserSOBIESKI, MESSER & ASSOCIATES900 S. Gay Street, Ste. 1801Knoxville, TN 37902

William A. Mynatt, Jr.SHEPPEARD & SWANSONP.O. Box 2149Knoxville, TN 37901-1249

Pamela M. Tulay9423 Yuma DriveKnoxville, TN 37931

this /7 ay of 2002./

JAMES R LAFEVOR

17


23/125

C C( COURT TRIAL NOTICFILE COPY

08/07/02


TULAY PAMELA MORITLvs.

TULAY MICHAEL PETER

CASE No: 01-151759 PLEASE BE ADVISED THEABOVE STYLED CAUSE IS SET FOR TRIALAT 9:30 ON 21ST DAY OF MARCH 003


NOTICES SENT TO

NATT WILLIAM &. JR. ESSER, DIANE MBIESLI, WANDA G.

18


24/125

p1 I L E D

IN THE CHANCERY C OURT FOR KNOX COU NTY, TENNESSEE

2 0 0 2 A U G 2 6 P Kl: 36

PAMELA MORTTZTIJLAY,

Plaintiff,

vs.


Defendant.

HOV4 G. HOGAN

No. 1517 59-3

MOT ION FOR INCLUSION OF LANGUAGE REFLECT ING ATTORNEY'S LIEN

James R. LaFevor, moves the Court to include an acknowledgem ent and protection of his

statutory attorney's lien in any Final Judgm ent of Divorce granted in th is cause. In support of the

m otion, he will show as follows:

1 . James R LaFevor w as attorney of record for Pame la Moretz Tulay.

2. James R. LaFevor and Pam ela Moretz Tulay entered into a written agreem ent

concerning representation whereby she agreed to pay fees for time spent. (Attached as

Exhibit A is a copy of the retainer agreement).

3 . James it LaFevor performed leg al services on behalf of Ms. Tulay and sub m itted

billings for those. (Copies of the Billings ma y reflect attorney-client informa tion andwill be subm itted in cam era for the court's review, if necessary.)

4. After negotiations and two lengthy m ediation sessions with John Harber, Pamela

Moretz Tulay decided that she would seek other counsel.

5 . James R. LaFevor has filed a Notice of Lien pursuan t to the statute.

6. Pursuant to court opinions, the lien needs to be m em orialized in any Final Judgm ent of

Divorce.

1

19


25/125

THEREFORE, Jam es R. LaFevor move s that he be granted a lien again st any assets of

Pam ela Moretz Tulay pendin g resolution of the attorneys fee issue.

Respectfully subm itted this ay of 2002.

JamIR.. LaFevor914LE and LAFEVOR

00 First Tennessee Plaza800 S. Gay StreetKnoxville, TN 37929865) 637-6258


This is to certify that a true and exac t copy of the forego ing Motion for Attorney's Lienhas bee n HAND DELIVERED to:

Diane M. MesserAttorney for Pamela Moretz TulaySOBIESKI, MESSER & ASSOCIATES900 S. Gay Street, Ste. 1801Knox ville, TN 37902

William A . Mynatt, Jr.Attorney for Michael Peter TulaySHEPPEARD & SWANSONP. 0. Box 21 49

Knoxville, TN 37901-1249

Mailed this ay of Au gust, 2002.


26/125

4 4

0 YFAMILY LAW FEES AND (OSTS AGREEM ENT

j l _~DATE: _______

CLIENT NAME: e -y 1 .

ADDRESS: 923 1'rv r 'v'eStreet PL

kk pi11 3JCity tate ip Code

HOME PHONE: 'T 0 1qffj WORK PHONE:PAGER/CELLULAR:fo (.,03 ACSIMILE:

RE:

INTRODUCTION

This document constitutes our agreement for me representing you in your failtily law matter. Please read itc.arefiully and call me if you have any questions. Discuss it with your regular family or business lawyer if youlike. If you find this agreement acceptable, please initial each page, sign on page 3, and return it to me w i thyour retainer for $2,000.00. Receipt by me will initiate m y representation of you.

COUNSELING

If you are not in counseling, I recommend that you consider it. The length and expense of the case is usuallyaffected by the intensity of the parties' feelings. During a divorce or custody dispute many people experienceemotions tha t are difficult to handle without professional help. I find that the money invested in psychologicalhelp is well spent because the client is better able to cope with the stress of the case. Counseling often results inreduced attorneys' fees.

ADVANCE PAYMENT

A minimum $2,000.00 plus f i l ingfees advance payment is required. if the case involves disputed custodymatters, it is often more expensive and a payment of $3,500.00 may be required, depending upon the

circumstances . I will place this retainer in the client trust account and bill you against thi s monthly. A 1)811 of

this $2,000.00 retainer is tion-refundable, namely, $700.00 in legal fees and a $60.0 ) case administration

fee which includes opening, copies, postage and local faxes. Express or certified mail, ITedex, and longdistance phone/lax are charged at cost. Example: Assume I complete 3.0 hours of work ($600.00). Yourcosts would be the $700.00 minimum attorney labor charge and $60.00 case administration fee, for a total of$760.00, trorn the $2,000.00 advance l)ayflleImt,$1,240.00 would be left in your trust acount. At the

conclusion of m y representation of you, and after all charges are entered against your re airier, the remainder, ifany, in the client trust account will be refunded to you. If the balance in the client trust account is depleted

before the completion of the case, you areto replenish it, unless we have reached a sepal ate written agreement

otherwise. if you have any question about your bill, please call nrc.

CHARGES

My present hourly rate is $200.00, and $50.00 per hour for my legal assistant. These rates may increase from

time to time. I compute a minimum of one-tenth (1110)of an hour for each telephone call, no matter how shorti t sduralion. Additional time is recorded in tenths or all hour. Written coil ununicalions are encouraged because I

read faster than I can talk. Also, written coimurmuiricatiOil creates a record for the file.

Under Tennessee ethics rules, clients must bear expenses of litigation. Therefore, in ad hition to these fees, you

also will pay out-of-pocket costs incurred in your case. The costs include: court filing lees, long-distancefaxes/phone calls, computer research time, process servers, court reporters, witness fees, travel, experts andinvestigators. I will not hire experts or investigators unless you agree that they should be hired and that you paydirectly to the expert or investigator their fees as incurred.

Page 1 of 3 r"ITIALSJDATFe x

A


27/125

TOTAL BILL

I do not know how m uch t ime y our case wi l l take , because I do not know what the d isputed i ssues wi l l be norhow long neg otiat ions or tr ial preparation wil l last. Your cooperation in providing information and in workingviih ine on your case can considerab ly expe dite the case and help red uce at torney's fees. Call me as often as you

like, but please keep in m ind that telephone calls do increase your expenses (al though n ocj .iMgewillbe made fortelephone calls or in-person conferences regard ing your b i l l s) . It m ay cos t less i f you keep me updated by m ai l,how ever, i f your inform ation needs prom pt at tention, please call or fax information to ore r ight aw ay.

PAYMENT OF LEGAL FEES BY OPPOSING PARTY

Some t imes the cour t wi l l o rder the o ther par ty to pay your leg a l fees and cos ts . An order i s m ore l ike ly to issuewh en one party has substantial ly more incom e and assets than the other party. In approp riate circum stances, I

wil l ask the cour t to order the o ther par ty to pay your fees and cos ts. l fyou are l I re )a r ty w i lh more incom e andassets , tIre court ma y order M u to pay al l or a port ion of the opposing party 's fees.

This cont rac t i s be tween y ou and m e. You are u l t im ate ly respons ib le for paym ent of the lcs and cos ts awardedto me, even i f the Cour t aw ards an a t torney ' s fee . You wi l l rece ive re imbursem ent for paym entsYOU have madein tlr_ggt the other party pays as ordered, or if you have an outstanding haance owing to me, the paymentswillbe cred ited to your balance . If the other party fai ls to pay as ordered an d you d esire to start a collect ion orcontemp t ac t ion , such an ac t ion would be a n ew an d separa te case . I f such an ac t ion we re not brought as asepara te case , it would m ean tha t I would incur fur ther cos ts in co l lec ting the fees and cos ts owing to rue . Thereare at torneys wh o special ize in collect ion, I do not .

LATE CHARG ES, LIENS AND CREDIT SERVICES

Please pay you r bi l l on receipt of the statem ent. If the bil l is not paid prom ptly, your balance sh all hear a one andtwo- ten ths (1 .2) percent m onth ly la te charge (which equ als 14 .4% per year A PR) i f you do n ot pay the ba lanceowe d w ithin thir ty (30) days. Upon notice, the interest wil l at tach at the end of each bil l ing cycle u nti l t ire entireh i l l is pa id . I am not a f inancia l ins ti tu t ion . I s trongly recom m end tha t my c l ien ts sek m ethods of f inancing thecnsc that avoid p aym ent of interest at this rate. If i t is nece ssary for me to ini t iate act ions to collect fees, youagree to p ay the co lkc t ion cos ts tha t I incur for a t torney fees an d ex penses . Any checks re turned for insuffic ien thinds shall be charged an y applicable bank lees plus a $25.00 returned check fcc.

Upon signing this agreem ent, pending p aym ent in ful l , m y fee is secured by a l ien on your share of the real andpersonal prop erty division.

CLIENT DUTIES

You, as the c l ien t , agree to te l l me the t ru th , to keep m e advised of your address and te lephone num ber, to

cooperate in the prep aration and tr ial of the case, to appe ar on reasonable notice for court appearances anddepos i tions , to pay prompt ly w hen y ou rece ive a s ta tement , and to com ply w i th a l l reasonable reques ts m ade ofyou in conn ection with the prep aration and presentat ion of this matter with m e, and I agree not to set t le orcomprom ise your c la ims w i thout your consent , except in ex t reme em ergencies to Pro tec t ou t in te res t.

PARENTING EDUCATION SEMINARS

Tenn essee Code A nnotated 36-6-408 requires that the parents at tend a sem inar as soon as possible after f i l ingof the comp laint , for a minim um of four hours. You wil l bear this responsibil i ty and cost . Fees ma y be w aivedbr ind igen t persons .

NO GUARANTEES OF OUTCOME

You acknowledge tha t I have made no guarantees regard ing the outcome of your case or about i ssues tha t mayhe dec ided by the cour t pr ior to a f ina l ru l ing . S ta tements tha t I make regard ing the l ike ly outcome or the rangeOf possible outcomes are only m y opinion not a guaran tee of results .

cr r1+7 1D I 2Page 2 of 3 flTIALS/DATE


28/125

SCOPE OF REPRESENTATION

The provisions of this agreement shall apply only to the matter referenced above and, unless otherwisespecifically provided, my representation oIyou shall he for trial court proceedings only. If appellate proceedingsarc instituted, or if you want to institute appellate jrrocccdiiigs, additional fee and ictainer ;igrectncnls inut hemade. If I continue to represent you after final judgment or after our initial undertaking is ;ompleied. all of theseprovisions shall apply, and we shall each be bound by these terms, unless we have a writicti agreement to the

contrary.

Effective January 1, 2001, Tennessee has enacted a new parenting plan requirement, which also calls for

alternative methods of dispute resolution. Charges will be incurred for all representation on dispute resolution.A Permanent Parenting Plan is required in all cases involving children.

DISCHARGE AND WITHDRAWAL

You have the right to discharge me as your attorney at any time. I have the right to withdraw as your attorney(or seek permission from the court to withdraw as your attorney) if you nhisrqpresent or fail to disclose a materialfact to me; if you fail to follow my advice; if you fail to make payments as required by this agreement: or ifyoridemand that I do something unlawful, unethical, or against my moral belief.

1 l'you require your file to be turned over to you, I must maintain a copy. Therefore, you will need to pay thecosts of copying.

CONFIDENTIALITY

Communications with me and my assistants concerning your case are generally confidential and are protected

Front disclosure under attorney-client privilege rules. This privilege is not absolute, and I may be re quired to

reveal irnlormiflion II' necessary to prevent a crime or fraud. Your privilege of confidentiality can also be lost if

you discuss our communications with oilier persons. lithe court is asked to decide the is:ue of attorney's fees inIris case, this agreement may be disclosed to the court. If, at any time, you have questions about confidentiality,

please call ine to discuss them.

CLOSING

I look forward to representing you in this matter. We welcome and encourage your input and suggestions.

Signed this ?D ay ofit,1W1 2001.

/ACCEPTED BY: I lUYhJL V t[CLIENT

An

ES R. LAFEV(R, ATTORNEYKLE & LAFEVOKAssociation and not a Partnership)

1900 First Tennessee Plaza

800 S. Gay Street

Knoxville, TN 37929

Telephone: (865) 63 7-6258

23


29/125

0IN THE CHANCERY COUR T FOR KNOX COUNTY, TENNESSEE

PAMELA MORITZ TULAY,

Plaintiff;

vs.


Defendant .

No. 15 17/

NOTICE

That James K LaFevor wil l appear before the Ch ancellor on the 3rd of Septem ber, 2002,

on a m otion concerning a l ien for at torney's fees.

Respectful ly subm itted this 26th day of Au gust , 2002.

LaFevor (. Jand LAFEVOR

9OO First Tennessee Plaza800 S. Gay StreetKnoxvil le , TN 37929(865) 637-6258

24


30/125


This is to certify that a true and exac t copy of the foreg oing Notice has been HANDDELIVERED to:

Diane M. MesserAttorney for Pamela Moretz TulaySOB1ESKI, MESSER & A SSOCIATES900 S. Gay Street, Ste. 1801Knoxv ille, TN 37902

William A . Mynatt, Jr.Attorney for Michael Peter TulaySHEPPEARD & SWANSONP. 0. Box 2149Knoxville, TN 37901-1249

DATED this ay of Au gust, 2002.

2

25


31/125

CHC( OURT TRIAL NOTICFFILE COPY

10116/02


TULAY PAMELA MORITZVS.

TULAY MICHAEL PETER

CASE NO: 01-151759 PLEASE BE ADVISED THEABOVE STYLED CAUSE IS SET FOR CONTEMPTAT 9:30 ON 20TH DAY OF DECEMBER 002


NOTICES SENT TO

NATT WILLIAM A., JR. ESS ER, DIANE MOBIESI, WANDA G.

W .


32/125

CCERY COURT TRIAL NOTICFILE COPY

03/06/03

CHANCERY COURT CLERK400 MAIN STREET, CITY-COUNTY BLDGK\0XVILLE, TN 37902

TULAY PAMELA MORITZVS.

TULAY MICHAEL PETER

CASE NO: 01-151759 PLEASE BE ADVISED THEABOVE STYLED CAUSE IS SET FO R CONTEMPTA1 9:30 ON 21ST DAY OF APRIL 003


NOTICES SENT TO

MYNATT, WILLIA 1 A., JR. ESSER, DIANE MSOBIESKI, WANDA G.

27


33/125

1 E

IN THE CHANCERY COURT FOR KNOx COU NTY, TENNESSEE

PAMELA MORITZ TIJLAY

PLAINTIFF

VS O. 1S1759-3

MICHAEL PETER TULAY

DEFENDANT

SHOW CAUSE ORDER

TO THE SHERIFF OF K NOX COUNTY:

AND TO: MICHAEL PETER TULY

GREETINGS:

You are hereby notified, by Fiat of Chancellor Sharon Bell

to appear in the Chancery Court

Room of K nox .County, on ecember 2 0 002 at

9 : 3 0 a . m . nd show cause, it any you have, why you

should not be held in contempt of the Order of this Court.

This 18th ay of ctober 202

4Clerk and Maste

I CERTIFY THAT I SERVED THE WITHIN SHOW CAUSE ON THE /2 DAY OF0 -- 4-n he r 20Q, BY DELIVERING A COPY OF THE PETITION AND SHOW

CAUSE TO THE DEFENDANT

f FAILED T BELOW WITHIN THIRTY 30)DAYS AFTER ISSUANCE BECAUSE

CIA

DEPUTY S2EIIFF

28


34/125

STATE OF TENNESSEETHE CHANCERY COURT FOR KNOX COUNTY l

PAMELA M ORITZ TULAY,

PlaintiffPetitioner,V.


I)efcndantfRespondent.

No. 9-31517

To the above named Defendan t (Responden t :You are hereby summoned and required to serve upon Wanda G. Sobieski

attorney, whose address is Sobieski, Messer & Associates. Riverview Tower, 900 S. GayStreet, Suite 1801, Knoxville, Tennessee 37902, an Answer to the Petition for Contemptherewith served upon you within thirty (30) days after service of this Sunir1soiis andComplaint upon you, exclusive of the day of service. If you fail to do so, judgment bydefau l t can be t aken aga ins t you fo r the re l i e f demanded in the Com pla in t .

issued and tested this ay of e-? .te'

,44- .b AcClerk

DeputyL erk

NOTICETo the Defendan t(s) :

Tennessee law provides a Four Thousand Dollars ($4000) personal propertyexemption from execution or seizure to satisfy a judgment. if a judgment should been te red aga ins t you in th i s ac tion and you wish to c la im proper ty as exem pt , you m us t f il ea written list, under oath, of the items you wish to claim asxempt with the clerk ef thecourL The list may be filed at any rime and may be changed by you thereafter asnecessary; however,unless it is filedbefore the judgment becomes final, it will not beeffective as to any execution of garnishment issued prior to the filing of the listCertain itenis are automaticaity exempt by law and do not need to be listed; these includehems of necessary wearing apparel for yourself and your family and trunks or otherreceptacles necessary to contain such apparel, family portraits, the family Bible, andschool books. Should any of these items be seized, you would have the right to recoverthem, if you do not understand your exemption right, or how to exercise it. you maywish to seek the counsel of a lawyer. Tenn. Code Ann. 26-2-114.

SERVICE INFORMATIONTo the Process Server: Michael Peter Tulay can be served through his attorney of

-record, Wil l iam A. Myn ati , Jr. a t Shepp card & Swan son, 616 W. Hil l Aven ue, Knoxv il le ,Tennessee 37902.

R E T U P NI rece ived th i s summ ons on the- I _day o f Oc , z ,_

I he reby ce r t i fy end re tu rn tha t on theled-

(X served this summons and a P.c-fs--fL 6- _ ) 1 in the fo l lowing m anncr : ec -)_c_i

fai lee - tb seve t tns so fmor,s w ithin thir ty (30) days af ter i ts issuance be cause:

Process

29


35/125

CHILD SUPPORT SERVICES507 S G AY ST, SUITE 600KNOXVILLE, TN 37902

STATE OF TENNESSEE F L E DDEPARTMENT OF HUMAN SERVICES

(865) 862-0366FAX (865) 862-0403 200b APR 28 P 3: 5 L

H O WA R D H O G A NC/C BLDG. 400 MAIN A NFIRST -FLOO R1 SUITE 0 H O G A WKNOXVILLEi TN 3?902 -CLERK &MASTER

04/21/2006

RE: AMELA A. MORITZV. M1CH AL P. TLJLAYCHANCERY Court, Docket Ny 51759-3KNOX County, Tennessee

TCSES Case: 000836172

The enclosed Order/Notice to Withhold Incom e For Child Support is being provided to you pursuant toTennessee Code Ann otated, 36-5-501(b)(4).

30


36/125

CHILD SUPPORT SERVICES

507 S GAY ST, SUITE 600KNOXVILLE, TN 37902

(865) 862-0366

ME

STATE OF TENNESSEEDEPARTMENT OF HUMAN SERVICES

SEQUOY AH CO NSUL TING GROUP1]] WASHINGTON STP L A IN V IL L E , MA 0 2 7 6 2 - 1 5 5

ORDER/NOTICE TO WITHHOLD INCOM E FOR CHILD SUPPORT

RE: AM ELA A. MOR ITZ v. MICHAEL P. TULAYCHANC ERY C ourt , Docket No. 151759-3

KNOX County, Tennessee

TCSES Case: 000836172

REMITTANCE INFORMATION

With your remit tance y ou m ust provide the paym ent Turnaround Document (Em ployer Obligat ionLetter) provided to you by the Departm ent of Huma n Services, or you m ust provide all of the followinginformation.

Date paym ent was deducted f rom Em ployee 's /Obl igor 's nam eem ployee's/obligor 's income

Docket number Em ployee 's/Obligor 's Social Securi ty num ber Court identifier Em ployee 's /Obligor 's re turn add ress

PLEASE CONTACT THE OFFICE LISTED ABOVE IF YOU HAVE QUESTIONS ABOUT THIS NOTICE

3 1


37/125

JJ ORDER/NOTICE TO WITHHOLD INCOME FOR CHiD SUPPORT

0NOTICE OF AN ORDER TO WITHHOLD INCOME FOR

CHILD SUPPORTORIGINAL MENDED D TERMINATION ate: _04121/2006

State/Tribe/Territory TENNESSEE

City/Co./Dist./Reservation KNOX

Non-governmental entity or Individual

Case Number CHANCERY 1 151759-3

SEOUOYAH CONSULTING GROUPEmployer's/Withholder's Name

111 WASHINGTON STEmployer's/Withholder's Address

PLAINVILLE, MA 02762-2155

Employer's/Withholder's Federal EEN Number (if known)

RE: TIJLAY. MICHAEL P.

Employee's Obligor's Name (Last, First, ME)J67-"- '5376

Employee's/ Obligor's Social Security Number000836172

Employee's/ Obligor's Case IdentifierMORITZ, PAMELA A.Obligee's Name (Last, First, MI)

ORDER INFORMATION: This document is based on the support or witholding order from TENNESSEEYou are required by law to deduct these amounts from the employee's/obligor's income until further notice.

3.900-00 er _MONTH urrent child support.950,00 er MONTH ast-due child support Arrears greater than 12 weeks? 0 yes 0 no

Per__________________ _ current cash medical supportPer ast-due cash medical support

S ___________________ Per pousal supportS ___________________ Per ast-due spousal supportS ___________________ Per ____________________ other (specify)

for a total of S5,850.00 er MONTH o be forwarded to the payee below.

You do not have to vary your pay c ycle to be in compliance with the support order. If your pay cycle does not match the orderedpayment cycle, withhold one of the following amounts

S ,350.00 per weekly pay period. 2,925.00 per semimonthly pay period (twice a month).

$ ,700.00 per biweekly pay period (every two weeks). 5,850.00 per monthly pay period.

REMITTANCE INFORMATION: When remitting payment, provide the pay date/date of withholding and the case identifier. If theemployee's/obligor's principal place of employment is Tennessee, begin withholding no later than the first pay period occurring 14

working days after the date of 0412112006 . Send payment within 7 working days of the pay date/date of withholding. The total

withheld amount, including your fee, may not exceed 50'V0 of the employee's obligor's aggregate disposable weekly earnings.

IF the employee's/ obligor's principal place of employment is not Tennessee, for limitations on withholding, applicable time requirements,

and any allowable employer fees, follow the laws and procedures of the employee's/obligor's principal place of employment (see #3 and

# 9, ADDITIONAL INFORM ATION TO EM PLOYERS AND OTHER WITHHOLDERS).

Make check payable to: TENNESSEE CHILD SUPPORT end check to: RECEIPTING UNITII remitting payment by EF T/EDI, call(800) 838-6911 efore first submission. .O. BOX 305200

Use this FIPS code: ank routing number._ Bank account number:_. ASHVII .i.v, m 17229

If this is an O rder/Notice to Withhold:

Print Name Michael 1.. AdamsTitle of Issuing Official Assistant Commissioner, Child Support

Signature

Date 412112006

IS IV-D Agency CourtU Attorney with authority under state law to issue order/notice

If this is a Notice of an Order to W ithhold:

Print NameTitle (if appropriate)

Signature

Date

U Attorney U Individual Private Entity

NOTE: Non-IV-D Attorneys, individuals, and non-governmental entities must submit a Notice of an Order to Withhold andinclude a copy of the income withholding order unless, under a state's law, an attorney in that state may issue an incomewithholding order. In that case, the attorney may submit an Order/Notice to Withhold and include a copy of the state law

authorizing the attorney to issue an income withholding order/notice.

IMPORTANT: The person complet ing this Form is advised that the information on this form may be shared with the obligor. 2


38/125

AG p J R LH i

CHILD SUPPORT SERVICES507 S GA Y ST, SUITE 600KNOXVILLE, TN 37902 STATE OF TENNESSEE L L ZU

DEPARTMENT OF HUMAN SERVICES

2 0 0 b M A Y- 2 P 1:53(865) 862-0366Fax (865) 862-0403 ME

MICHAEL P. TULAYC9042 LEGENDS LAKEbKNOXVILLE, TN 37922-5258

ADM INISTRATIVE ORDER TO REDIRECT CHILD SUPPORT PAYMENTS

RE: PAMELA A. MORLTZ v. MICllAL P. TULAY

CHA NCER Y Court , Docket No/51759-3

KNOX County, Tennessee

TCSES NO: 836172

Pursuant to T.C.A. 3 6-5-803, you are herebyORDEREDto pay all future, support paym ents to

Central Child Support Rec eipting Unit , P. 0. Box 305200, Nashville, TN 37229. The paym ents

should include the following am ounts:

$3,900.00$.00$.00

. 0 0$.00$.00

$3,900.00

perperperperperperper

MONTH for current child sup port;MONTH for child sup port arrears;MONTH for current m edical supp ort;MONTH for m edical supp ort arrears;MONTH for current spousal supp ort;MONTH for spousal supp ort arrears;MONTHTOTAL AMOUNT

33


39/125

You must return with your payment the payment coupon provided by the Department of

Human Services. If you have not received one, contact Customer Service at 1-800-838-

6911. If you do not return the payment coupon, you must provide the following

information:

Docke t ID: 151759-3Court Identif ier : 4709305Your nameYour Social Security Number

Your re turn addressPursuant to T.C.A. 36-5-120, failure to include the information requested above may

result in a civ il penalty being issued aga inst you.

You are hereby notified that no credit shall be given for any paym ents ma de by you or by another

person on your behalf directly to the custodial parent. Such paym ents would be considered to be

a gift by you or pay men ts of an obligation other than those listed above.

It isF U RT H E R O R D E R E Dthat the parties com plete the required information found in Exhibit

A to this order. You m ust provide the information im m ediately to the local child support office

listed above. Additionally, you are req uired to notify the Child Sup port Office listed on Exh ibit

A of any chan ges in the information on Exhibit A within ten (10) days of the change.

You m ay ap peal this Adm inistrat ive Order by f i l ing a w ri tten request for an adm inistrat ive

hearing w ith the child support office shown above w ithin fif teen (15) calendar days of the entry

date of this order. The only ground s for app ealing this order are: a mistake of identity, a m istake

of fact, or that this c ase is not a Title IV-D case.

Failure to obey this Adm inistrative Order m ay result in the im position of civil pen alties, and /or

imp risonmen t for contemp t, or suspension of your d river's or other licenses.

If you have an y que stions concerning this Adm inistrative Order, you should contact the child

supp ort office at the above address.

Enter this day of A24/2Z2

Title IVjYdininistrator / Supervisory D esignee

Adm inistrative Order to Redirect Child Support Paym ents - Page 24


40/125


I hereby cert ify that a copy of this ORDERwas served on MICHA EL P. TULAY, PAMELA A.

MORITZ, and the Clerk of CHANCERY Court of KNOX County by mailing to h im/her by

First Class U.S. Mail postage p repaid on 28 Apri l , 2006.

X ~ - ~ "e e--

Tit1u1V-D A dministratorI Supervisory De signee

Administra tive Order to Redirect Chi ld Support Paym ents- Page 35


41/125

FAILURE TO A PPROPRIATELY UPDATE THIS INFORMA TION OR GIVING FALSE INFORMATIO

COULD LEAD TO B EING CITED FOR CONTEM PT OF COURT OR HAV ING A DEFAULT JUDGMENT

ENTERED A GAINST YOU.

B OTH PARTIES MU ST UPDATE THE FOLLOWING INFORMA TION WITH ANY CH ANGES WITHIN

10 DAYS OF THE CHANGE TO THE C LERK OF THE CHA NCERY C OURT, C/C B LDG. 400 MAIN

AV ENUE FIRST FLOOR, SUITE 125, KNOXVILLE, TN 37902 AND THE C HILD SUPPORT SERV ICES,507 S GAY ST, SUITE 600, KNOXVILLE, TN 379 02:

Father's Information

Full Nam e: SN: _____ - ____ -

Last irst iddle

Residential Ad dress:

Mail ing Add ress:( i f different from above)

Phone: ( )

Birthdate: -

B ir thplace -City: ____

State:

I

Drivers License

LIp1o\ersNarne hoe ___

Em ployee s AJ&ess . ros ilk on I

fleLlIk.

Available through Em ployer?

Health Insurance ) Yes ) No

Company:

Health Insurance

Address:

Cost to Employee ( if any):


42/125

Mother's Information

Fall Name:

1 at iddIe

Reidential Ades: hone:

Birthdate:

Mail ddr:irthplace -

(it J tIeren 1rn aho\e)ate

- )ri er T icene T7:

Employer's Name: hone:

Employer's Address:ross Income:

Tota l Gross Income:

Avail iNc ihroug ) p10

Health Iurance )YS ) No

C o m p a n y :

Health baiance

Address:Cost to En plor cc (it any:

37Demographic Information - Page 2

M


43/125

Child(ren)'s Information

(1)Child's Full Name: SN:

Last irst iddle

Residential Address: irthdate:

(2) Child's 1u1lName:

Last irst iddle

Residential ddre: rthdats: -

(3)Child's Full Name: SN:

Last irst iddleResidential Address: irthdate:

(4) Child's full amc:

Last irst iddle

Residental ddrss rthdaie:

(5) Child's Full Name: SN:

Last irst iddle

Residential Address: i r thdate: - /

Demographic Information - Page 3 8


44/125

NON-RESIDENT NOTICE

TO: PAMELA(

t

PAMELA MORITZ TIThAY VS- MICHAEL PETER TTAY

No: 1 5 1 7 5 9 - 3 \ /

IN THE CHA NCER Y COURT OF KNOX COUNTY, TENNESSEE

In this cause,it appearing from the Com plaint f iled, which is sworn to, that the defend ant

PAMELA MO RITZ TITLAY on resident f the State of Tennessee, or

whose w here-abouts cannot be ascertained upon dil igent search and inquiry, so that the ordinary process

cannot be served uponHER t is ordered that said defend ant fie an answer w ith the Clerk and

Master of the Chancery Court at Knoxville, Tennessee and w ithKIMBERLY R . TAYLO R

Plaintiff s Attorney w hose add ress is7 2- I r K ingston Pike. Suite 703 ,

Knoxvi lle, Tennessee 37 9 2 2 ithin thirty3 days of the last date of publication

or a judgm ent by default will be taken againstyou nd the c ause set for hearing Ex Parte as to

you This notice w ill be pu blished in theREADING EAGLE or four (4)P. 0. Box 582, Reading, Pennsylvania 19603-

consecutive week s. 5 8 2 3 7 111 el: (610) 371-5100

This 7th ay of ay 2007

C T


45/125

{ No. 1405442 007

Proof of Publication of Notice in Reading EagleUnder Act No.587, ApprovedMay 16,1929.

Comm onweal th of Pennsylvania ,County of Berks ss: U1HSCP 18

9:Q7

u G. HOGN'1Jo Mm Gottschall, Assistant Secretary, REA DING EAGLE COM PANY, of the County and C om mon wealth aforesaid, being duly sworn,deposes and says that the REA DING EAGLE established January 28, 1868 is a new spaper of gene ral circulat ion published at 345 PennStjeet , City of Reading , County an d State aforesaid, and that the printed notice or publicat ion at tached hereto is exactly the same as printand p ublished in the regular ed it ion and issues of the said REA DING EAGLE on the fol lowing dates, viz.:

Reading Eagle unday, May 20, 2007, A.D.Reading Eagle unday, May 27, 2007, A.D.

Reading Eagle unday, June 3,2007, A.D.Reading Eagle unday, June 1 0, 2007, A.D.

Effective July 1, 2002 Reading Time s Ceased Publicat ion. The Reading Eag le wil l be a daily morning an d Sunday e dit ion.

Affiant further deposes that this person is duly authorized by R EADING EAGLE COM PANY, a corporation, publisher of saidREA DING EAGLE, a newspa per of gen eral circulat ion, to verify the foregoing statemen t under oath, and aff iant is not interested in thesubject ma tter of the aforesaid notice or advert isemen t, and that al l al legations in the foregoing statemen ts as to t ime, place, character ofpublicat ion are true.

Cop y of Notice or Publicat ion y1Jo AnnCiottschall

Sworn to and subscribed before me this 10 th dayN o 1 4 . R E S I D E N r . N a T t c - -

IN THE

MO RITZ7ULAY)

'MoRrrZ -ULAY) - VIETEP TULAY

511CC-I

46ERY COURTC COUNTY.lESSEE -

of June ' 2007

07- M - - - - - - - - - - - - ----- -NotaryStatement of Advertising Costs

KIMBERLY R TAYLOR ESQ9724 KINGSTON PIKESUITE 703KNOXVILLE, TN 37922

MORITZ VS TULAYCOMMONWEALTH OF PENNSYL\'A

NOIARIAL SEALA N N L . L IP TA K N O T A R Y P U B L I C

C I T Y O F R E A D I N G , B E R K S C O U N T YM Y C O M M I S S IO N E X P I R E S O C T 2 , 2 0 0 8

To READING EAGLE, DR:

I

cane set lc( 40a,rM exjlarreas ID y o d Ths ouBce wdl bepublished n - the READINGEAGLE P.O. Boxin. Reaa'ng,PernuyJvania 19603.058ZI Tel:(610) 371-1OC f four (4)cgnsecutive weeIc.

ThhiilIt day a ' May, 2L07,

14p,.,4 e. IIsnCLERK AND MASTER

For publishing the notice or publicat ionattached hereto on the above slated dates 624.00Probating same 5.00Total 629.00

Publisher's Receipt for Advertising CostsTheREADING EAGLECOMPANY, publisher of theREADING EAGLE,a newspaperof general circulation, hereby acknowled ges receipt of the aforesaid notice andpublication costs and certifies the same have been d uly paid.

READING EAGLE COMPANY, aCorporation 0


46/125

J

CHILD SUPPORT SERVICES501 -S GAY ST, SUITE 400KNOXVILLE, TN 37902

STATE OF TENNESSEEDEPARTMENT OF HUMAN SER IUS' 25

(865) 862-0366FAX (865) 862-0403

OWARD HOGANC/C BL DG. 400 MAIN AVENUEF IR S T FL O O R , S U I T E 1 2 5K N O X V I L L E , T N 3 7 9 0 2

0 9 / 1 9 / 2 0 0 7

RE: AMELAA. MO RITZ v. MICHA EL P. T14,AYCHANC ERY Court , Docket No.1 5 1 7 5 9 - 3 IKNOX County, Tennessee

TCSES Case: 0 0 0 8 3 6 1 7 2

The enclosed Order/Notice to Withhold Income For Child Support is being p rovided to you p ursuant toTennessee Code Annotated, 36.5-501(b)(4).

41


47/125

A.

CHILD SUPPORT SER VICES GRWU ) R E

507 S GAY ST, SUITE400KNOXVILLE , TN 37902 7 V

STATE OF TENNESSEEDEPARTMENT OF HUMAN SERVICES

865) 862-0366

SEQUQYAH CONSULTING GROUP153 PLEASANT ST STE 4ATTLEBORO, MA 02703-2444

MOD IFIED ORDER/NOTICE TO WITHH OLD INCOME FOR CH ILD SUPPORT

PAMELA A. MORITZv. MICHAEL P. TULAYCHANC ERY Court , Docket No.1 5 1 7 5 9 - 3

RE: NOX C ounty, Tennessee

TCSES Case: 0 0 0 8 3 6 1 7 2

IMPORTANT NOTICE***

A . The At tached Order M odifies An Existing Income Assignment Or der

The am ount shown on the first page of this order is the new total that y ou should deduct. This newamount should be substituted for, and not added to the amount y ou were previously ordere d todeduct for t his partic ular tribunal/ease number.This modification does not affect any other deductionsyou m ay have been ordered to m ake for any other case(s) involving this same obligor/emp loyee.

E If this box is checked, you are no longer re quire d to withhold income for t his employe efobligorfor the ca se specified at the top of the first page of the order.This order to stop de ducting from thisem ployee's/obligor's incom e only affects the case specified in the attached ord er. It does not affect another deductions you may have been ordered to make for any other cases involving this sameemployee/obligor.

B. Remitta nce InformationWith your remittance you must provide the paym ent Turnaround Documen t (Employer ObligationLetter) provided to y ou by the Department of Hum an Services, or you must provide all of thefollowing information.

Date payme nt was deducted fromem ployee's/obligor's incom e

Docke t num ber Court identif ier

Em ployee 's /Obligor 's nam e

Em ployee's/Obligor's Social Security n um ber Em ployee's/Obllgor's return add ress

42PLEASE CONTACT THE OFFICE LISTEDABOVE IF YOU HAVE QUESTIONS ABOUT THIS NOTICE


48/125

ORDER/NOTICE TO W ITHHOLD INCOME FOR CH ILD SUPPORT0 NOTICE OF AN ORDER TO W ITHHOLD INCOM E FOR CHILD SUPPORT

0 ORIGINAL (] A M E N D E D [J TERMINATION ate:_09/19/2007State/Tribe/Terri tory TENNESSEECity Co.jDist.jkeservation KNOXNon-governmental entity or IndividualCase Number CHANCER YI 151759-3

SEOUOYAH CONSULTING GROUPEmployer's/Withholder's Name

153 PLEASANT ST STE 4Employer's Withholder's Address

ATTLEBORO, MA02703-2444

Employer's/Withholder's Federal EJN Number (if known)

RE: TIJLAY, MICHAE LP.Employee's/Obligor's Name (Last, First, MI)

167-44-5 376Employee's/Obligor's Social Security Number

000636172Em ployee's/ Obligor's Case Identifier

MORITZ, PAMELA A.Obligee 's Name (Last , First , MI)

ORDER INFORMATION: This document is based on the support or witholding order fromTENNESSEEYou are required by law to deduct these amounts from the e mployee's/obligor's income until further notice.$ .025.00 er MONTH urrent child supportS _____________________ Per ast-due child support Arrears grea ter than 12 weeks?0 yes 0 oS _____________________ Per ______________________ current cash medical supportS ____________________ Per as t -due cash medica l suppor tS ____________________ Per pousal supportS ____________________ Per ast-due spousal supportS ______________ er _____________________ other (specify)for a totalof $ ,025.00 er MONTH to be forwarded to the payee below.You do not have to vary your pay cycle to be in compliance with the support order. If your pay cycle does not match the orderedpayment cycle, withhold one of the following amounts:

S236.53 per weekly pay period. 1250 per semimonthly pay per iod (twice a month).$473.07 per biweekly pay period (every two weeks). ,025.00 per monthly pa y period.

REMITTANCE INFORMATION: When re mitting payment, provide the pa y date/date o f withholding and the case identifier. If theem ployee's/obligor's principal place of employ me nt is Tennessee, beg in withholding n o later than the first pay period occurrin g14working days a fter the date of 09119/2007.Send payment w ithin7 working days of the pay date/date of withholding.The totalwithheld amount, including your fee, may not exceed 50% of the em ployee's/obligor's aggregate disposable wee kly ear nings.

If the employee's/obligor's principal place of employment is not Tennessee, for limitations on withholding, applicable time re quirements,and any allowable employer lees,follow the laws and procedures of the employee 's/ohligor's principa l place of em ploym ent (see#3 and#9, ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER W ITHHOLDERS).

Make check pay able to:TENNESSEE _CHILD SUPPORT end check to: RECEIPTINGUNITIF rem itting payment by EFT/EDI, call (800)838-6911 efore first subm ission. .O._ BOX 305200Use this FIPScode: - Bank routing number:_ Bank account aumber:_. AHVTI J& TN 17 7 29

II this isan Order/Notice toWithhold:Print Name M,ehapl I A dameTitle of Issuing Official Assistant Com missioner, Child Supp ort

SignatureDate 911912007

IV-D Agency Court

0 Attorney w ith authori ty und er s tate law to issue order/notice

If this isa Notice ofan Order toWithhold-Pr in t Nam eTitle ( i f ap propriate)

SignatureDate

0 Attorney 0 Individual Private Entity

NOTE Non-IV-D Attorneys, individua ls , and n on-govern m ental ent i t ies must subm it a Notice of an Order to Withhold andinclude a copy of the incom e withholding ord er unless, under a s tate 's law, an at torney in that s tate may issue an incom ewithholding order. In that case, the at torney m ay subm it an Order/Notice to Withhold and include a cop y of the state lawauthorizing the at torney to issue an incom e w ithholding order/notice.

IMPO RTAN T: The person completing this Form isadvised that the information on this form m ay be shared w iththe obligor. 3


49/125

- -

11/14/2007 09:06:30 age 1 of 1

Summary of NOTICES Printed

TTJLAY PAMELA M ORITZ VS. TULAY MICHAEL PETER

Case No: M-01-151759 Please be advised the abovestyled case is set for HEARING (HEA) at 09:30 AM onFriday, 11/30/2007.

MOYERS, MICHAEL W

Name ddress rial Notice Da te

TAYLOR, KIMBERLY R 724 KINGSTON PIKE / SUITE 703 KNOXVILLE, TN 379 22 11/30/2007

TULAY, MICHAEL PETER 042 LEGENDS LAKE LANE KNOXVILLE, TN 37922 1/3012007

44


50/125

12/04/2007 11:30:12 age 1 of 1

Summary of NOTICES Printed

TULAY PAMELA M ORITZ VS. TULAY MICHAEL PETER

Case No: M-01-151759 Please be advised the abovestyled case is set for HEARING (flEA) at 09:30 AM onFriday. 12/21/2007.

MOYERS, MICHAEL W

Name ddress rial Notice Date

TULAY, PAMELA MORITZ 164 HIGHLAND AV EMT PENN, PA 19 606 2/21/2007

TAYLOR, KIMBERLY R 724 KINGSTON PIKE / SUITE 703 KNOXVILLE, TN 379 22 12/21/2007

45


51/125

FROM :Southeast Branch Library AX NO. :961G55G669 . 20 2 27 5: 53FMP2

2164 Highland AvenueReading, PA 19606

December 20, 2007

Howard G. Hogan

Clerk and MasterChancery Court400 Main StreetSuite 125Knoxville, TN 37902

RE: Docket No. 151759-3

Dear Mr. Hogan,

A re-hearing in this case has been set for Friday, December 21,

2007 at 9:30 A.M.

However, due to a four-day (Sunday 12/16 through Wednesday12/19) loss of power due to a severe ice storm in Pennsylvania, andhaving to seek shelter elsewhere with my children, I am unable to attendthis re-hearing.

I appreciate the court's understanding in this matter. I hope thatthe re-hearing can be rescheduled for a future date.

Respectfully,

Pamela Moritz

This letter faxed to (865)215-2920on Thursday, December 20, 2007

rSn


52/125

ROM :Southeast Branch Library AX NO. :96106556669 :.20 2007 05:52PM Pt

,-, ~ 2(

To: ft o V

cuw ~ 0

n

0/0 no

C k -~ im - 1 C 7

F(Zow-

-

V'VL r

0 ace4-J 7 ~~ l l N

C l)i

47


53/125

I

\flENNESSEEDJE ii

PAMELA MORJTZ (forme rly TULAY),

Original Plaint iff7Respond ent ,nUN

V. ocket No. 151759-3'

MICHAEL PETER TULAY, ot ice of En t ry Reques ted

Original Defendant/Respondent .

MEDIATION ORDER

Pursuant to the A lternative Dispute Re solut ion Req uirem ents of the Perman ent Paren

Plan, the part ies shall engag e in m ediat ion with i - ; said med iation to ccur

not later than Apri z g , co 9 o at temp t to resolve al l m atters currently pending

before this Cou rt.

ENTER this 7 k day of 2007.

APPROVED FOR E NTRY:

I"H)S.SUjI.1010,skI :IJZ .iIh:

CERT1FCATEHow icgn bc.y cctiiy t:;at I ii3 a trae d

pE

N I

p{ ZM&Z

48(3 D r


54/125

01/07/2008 13:58:42 agel of 1

Summar y of NOTICE S Printed

TULAY PAMELA M ORITZ VS. TULAY MICHAEL PETER

Case No: M-01-151759 Please be advised the abovestyled case is set for TRIAL (TRI) at 09:30 AM onWednesd ay. 5/14/2008.

MOYERS, MICHAEL W

Name ddress rial Notice Da te

TAYLOR, KIMBERLY R 724 KINGSTON PIKEI SUITE 703 KNOXVILLE, TN 379 22 05/14/2008

TULAY, PAMELA MORITZ 164 KIGHLANDAV EMT PENN, PA 19 606 5/14/2008

49


55/125

F

C a s e N u m b e r:1. 5 1759-3 v/

it

State of TennesseeDepartment of StateDivision of Business Services

312 Eigh th AvenueNorth6th floor Wm. ft Snodgrass Tower

Nashville, Tennessee 37243

1/16/2008Date

70070220000300898172

Certifed Number

HON. HOWARD G. HOGANKNOX COUNTY-CHANCERY COURTROOM 125, C/c B LDG, 400 MAIN STKNOXVILLE, TN 37902-1805

R E : PAMELA MORITZTULAY

VS: MICHAEL PETER 1WLAY

Dear Clerk:

Enclosed are the following papers in the above styled case:

] riginal Summons

Affidavit and Endorsement

I egistered or Certified Return Receipt signed by:

PAMELA MORITZ

Registered or Certified letter returned undelivered with notation:

Sincerely:a "~

Riley C. Darnell

enclosures

Initials: Q . ECC: TAYLOR

S5-4210 (Rev. 12/96) A No. 1003

50


56/125

Im E

Case Number: 151759-3

AFFIDAVITand

ENDORSEMENT

1/1612008Date

70070220000300898172Certified Number

RE: AMELA M ORITZ TULAY

VS: ICHAEL PETER TULAY

I OB GRUNOW aving been duly authorized by Riley C. Darnell, Secretary of Stateof Tennessee, do hereby make oath on his behalf and under authorization as follows:

That on hursday. December27. 2007 , I received from the plaintiff the originaland certified copies of the Summons and Complaints issued against the defendant:

PAMELA MORITZ TLJLAY

wh ose address is :2164 HIGLANDAVENUE. READING, PA 19606and that on ednesday. January 02. 2008 I mailed by registered or certified return-receipt mail the certified copies of the Summons and Complaint to the defendant at the above ad-dress together with written notice that service was so made. I further make oath that the returnreceipt for the registered or certified letter was received at my office in Nashville, Tennessee, on

Wednesday. 3anuarv 16. 2008 and returned to NOX COUNTY-CHANCER Y COURT

of KNOXVILLE Tennessee on Wednesday. January 16, 2008

Riley C. Darnell

Subscribed and sworn to before me, f1

this 16TH ay of JANUARY 2008

NOTARY PUBLIC

My commission expires 1-4-2010

PC/?

f ST1TE\

I FITIC ) NOTARY

DUC

5 1


57/125

f ~

IN THE CHANCERY COURT FORKNOX COUNTY,TENNESSEE

PAME LA MORITZ TIJLAY,

Original Plaint iff /Respondent ,

I', ocket No. 15175 9-3


Original Defendant/Petitioner.

TO: PAMELA MOPJTZ TIJLAY2164 Highland Avenu eRead ing, Pennsylvania 19606

You a re he reby summ oned an d requ i red to se rve upon Kim ber ly R . Tay lo rPlaint iff 's at torney, w hose address is : 724 Kingston Pike, Suite 703

Knoxvil le , Tenne ssee 37922865) 693-3080

a t rue cop y of the an swer to the Pet i t ion for M odif ica tion of Ch i ld Sup por t and Pet i tion Modif ica tion of Permanent Parent ing Plan which i s herewi th served upon you, wi th in 30 after service of this summ ons upon you, exclusive of the day of service. You will file the origiwith the Court .

If you fai l to do so, judg m ent by d efault wil l be taken against you for the rel ief deman ded incomplaint .

Issued this /day of 007 at - .

Witness Clerk and Master of said Court, at office in Knox County, Tennessee, theday of 2007.

Clerk and Master

BY:Deputy Cle4 and M aster

(Thissummons is issued pursuant to Rule 4 of the Tennessee Rules of Civil Procedure.)

Lfl1

5


58/125

93

NOTICETO THE DEFENDANT(S):

Tennessee law provides a four thousand dollar ($4,000.00) personal property exem ption from exec ution or seizu

sat isfy a judgm ent . If a judg m ent should be entered against you in this action and you w ish to claim proper

exem pt, you m ust file a written list , und er oath, of the items you w ish to claim as ex em pt with the clerk of the c

The l ist may be f i led at any t ime and m ay be chang ed by you thereafter as necessary; however,unless it is filed

before the judgment becom es final, it will not be effectiv e as to a ny exec ution of garnishment issued prior to

the filing of the list.Certain i tems are au tomatically exem pt by law and do not need to be l is ted; these include i tem

of necessary wearing a pparel (clothing) for yourself and your fam ily and t runks or other receptacles necessa

contain such apparel , family portrai ts , the family B ible , and school books. Should any of these i tems be seized

would have the r ight to recover them. If you do not understand y our exem ption r ight or how to exercise i t you

wish to seek the coun sel of a lawyer.

Received this ay of 007,

Deputy Sheriff.

RETURN OF SERVICE OF SUMMONS

I hereby cer t i fy and return that on the _____ day of 007 , I served th i s summ ons and

Petition for Modification of Child Support and Petition for Modification of Permane nt Parenting Plan, the prop

Permanen t Parent ing Plan, Fiat and Injunct ion upon the R esponden t by

fa i led to serve this summ ons w ithin 30 days af ter i t s i ssuance because__________________________________

Sheriff-Deputy Sheriff/Private Proce ss Server

2


59/125

STATE OF TENNESSEE, KNOX COUNTYCHANC ERY COURT AT KNOXVILLE

INJUNCTION o. 157 59-3

MICHAEL PETER TULAY VS AM ELA MORITZ (formerly Tulay)PETITIONER EFENDANT

To the Sheriff of KnoxCounty - Greeting:

And to PAMELA MORITZ An d to al l Counselors, Attorneys, sol ic itors and Agen ts , and toeach and every one of them

Greet ing:

Whereas M ichael Peter Tulay has la tely f l ied a Pet i tion for Modif icat ion bi l l of Comp laint in said

Chancery Court a t Knoxvil le , against you, the said defendant to be rel ieved touching the m atter set for th in

sa id b i ll in wh ich i t i s charged tha t Pam ela Mor i tz your ac t ings and do ings in the prem ises a re con t ra ry to

equity and good conscience, and whereas, the Honorable Michael Moyers, Chancellor of the Chancery

Court a t Knoxvil le , Tenn. , in said State has ordered that an injunct ion issue, as prayed by com plaint .

Therefore, in considerat ion of said f la t , and of the part icular m atters in said Bil l set for th, you, the

said defendant and the persons before named, and each and every one of you, are hereby strictly

com m anded a nd enjoined, und er the penal ty of a contem pt of Court , f rom interfer ing with the Pet i t ioner 's

co-parent ing t ime an d r ights set for th in the Permanent Parent ing Plan proposed by the Father which h as on

this date been approved as a temporary Order, until the further order of the said Chancery Court in the

premises.

Witness my hand at off ice , this 21ST day of Decem ber, A.D. 2007.

CL AND MASTER

D. C.

I CERTIFY THAT I SERVED THE WITHIN INJUNCTION ON THE AY OF

_, 20,

BY DELIVERING A COPY OF THE PETITION AND INJUNCTION TO THE DEFENDANT

ERSONALLY,OR BY__________________

I FAILED TO SERV E THE DEFENDA NT(S) LISTED DELOW WITHIN THIRTY (30) DAYS

AFTERAFTER ISSUANCE BECAUSE

DEPUTY SHERIFF

54


60/125

Complete items 1, 2, tha 3. AlsocompleteItem 411 Restricted Delivery Is desired.

Print your name and address on the reverseso that we can return the card to you.

Attach this card to the back of the mailpiece,or on the front If space permits.

PAMELA M ORITZ TULAY2164 HIGLAND AV ENUEREA DING, PA 19606

A Signature

XAgent

0 Addressee

B. A ved by (Th*ted/me) Date DeIiv'

L -- . Is delivery address different from Item 1? 0 Yes

If YES, enter delivery address below No

0 Certified Mail 0 Express Mall0 Registered Return RecelptforMerthandlse

U i ll f ih u l lI / lnsumd.Mall 0* 0 0 89 8 1 7 2 * . Restricted Delivery? (ExtraFeO e s2.ArtlaieNumber

0070220 0003 0089 8172

PS Form 3811, February OO4 omestic Return Receipt 02595-C2-M-i54O

55


61/125

in

02/05/2008 18:39:39 age 1 of 1

Summar y of NOTICE S Printed

TULAY PAMELA M ORJTZ VS. TULAY MICHAEL PETER

Case No: M-01-151759 Please be advised the abovestyled case is set for HEARING (flEA) at 09:30 AM onTuesday, 4/1/2008.

MOYERS, MICHAEL W

Name ddress rial Notice D ate

TAYLOR, KIMBERLY R 724 KINGSTON PIKE / SUITE 703 KNOXV ILLE, TN 37922 04/01/2008

TULAY, PAMELA MORITZ 164 IUGHLAI'.DAVEM T PENN, PA 19606 4/01/2008


62/

Date post:	02-Jun-2018
Category:	Documents
Upload:	consuelo-bell
View:	219 times
Download:	0 times

Technical Record-1.pdf

Documents