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HomeMy WebLinkAbout97-01401 . ~ II) ~ ~ ..., "( ~ .. -.( . - .:) - .;; r '., ( i I ! y ,'. ;~i '{ f; :j, 1 ! .1'...". ',.- ,/ wi ~ ~ en ..-:1,' - ~ ~. ~~; ;: ~I-c' ..... , f2~; '~, rt,.- -"'t .-. :c ~- \; ~ l:!i~ ~h ~~~~ ~~ ~ ~I ~ ~~ .~ ~~iB '~ ' 5,,~ Or::. r:,)~ q~ J,. en ~)-;.~ tCZ,'O ".llI) , rn Q.. :;: a ~'- '. " -w:"# ...... . '.-';' . " ~ l:(,~ ',~ c; -~ I C\ (t ~; ~ ~~' ~ .~ ~ '............ ~ ~ ~ Jo.. \;i Iri ~ ~ ~'" t ,'~ 0: .. ,Y i ~I =: '- :!: ~ ~' III ~, I ~ ; a! ~ '" Y uS ~ ~ 0 ~ i ~ ii: III ~ . ~es ~~ l> f! a II ~ ~~ ~ ~ III I 5 i ~ ' ~ " ~ ....:. .- ~ . f"~ ~.- -- :: . . '.! . .. . '. . '. . . MARY MICHELE LINDSEY, PLAINTIFF v. IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY, PENNSYLVANIA 11' ~O NO. f7- /~D( ~ CIVIL ACTION - LAW CUSTODY / VISITATION ROBERT LEE TRUAX, JR., DEFENDANT ORDER OF COURT AND NOW, this ;X...}.... of Horc V, 1997, upon consideration of the attached complaint, it is hereby directed that the parties and their respective counsel appear before \'()....... \('\ a t~ \-...1, \'-'\n i 0. ....\\- . f\C , on the r'::::J,~ day of ~. ~~a:.....11 ESQu'\ Ie...- , the conciliator, \---\("'(\-.,(YI\t... \~5 ) PA A\r'\ \ , 1997, at -9: 00 o'clock ..C\.....m., for a prehearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older shall also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. FOR THE COURT: I (-b~) .t~.) 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 PIND OUT WHERE YOU CAN GET LEGAL HELP. OFFICE OF THE COURT ADMINISTRATOR CUMBERLAND COUNTY COURTHOUSE, FOURTH FLOOR CARLISLE, PENNSYLVANIA, 17013 (717) - 240 - 6200 VB IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY PENNSYLVANIA : NO. (( 7. /'fo/ ~ ,-.......- MARY MICHELE LINDSEY, PLAINTIPF . . ROBERT LEE TRUAX, JR., DEFENDANT CIVIL ACTION . LAW : CUSTODY COMPLAINT FOR CUSTODY MODIFICATION 1. plaintiff is MARY MICHELE LINDSEY, who currently resides at, 42 West Locust Street, Mechanicsburg, Cumberland county, Pennsylvania, 17055. 2. Defendant is ROBERT LEE TRUAX, JR., who currently resides at, 2766 Rock Creek Parkway North, COrdova, Tennessee, 38018. 3. The parties obtained a divorce with the Plaintiff, MARY MICHELE LINDSEY, designated as the primary Custodian of the minor child, BOBBIE MICHELLE TRUAX, in the state of Tennessee on July 10, 1987. (Please see attached certified copy of the Divorce/Custody Order) . 4. The parties agreed the Plaintiff and their minor child could leave the jurisdiction of the state of Tennessee in July, 1995. 5. Plaintiff is presently requesting that this Honorable Court assume jurisdiction of this custody matter pursuant to PA.R.C.P. 1915.2 (a) (1) (i), 1915.2 (a) (1) (ii), and 1915.2 (a) (2). 6. plaintiff seeks Full Legal and primary physical custody of the following child: NAMES ADDRESS DATE OF BIRTH BOBBIE MICHELLE TRUAX 42 West Locust Street July 18, 1984 Mechanicsburg, PA 17055 The child was not born out of wedlock. The child is presently in the custody of the Plaintiff, Mary Michele Lindsey, who resides at 42 West Locust Street, Mechanicsburg, Cumberland County, pennsylvania, 17055. Since the last custody order, (Please see attached Certified Divorce/Custody Order dated July 10, 1987, from the state of Tennessee), the child has resided with the following persons and at the following addresses: I I I I 'I I I , ! PERSONS ADDRESSES DATES Memphis, Tenn. 7/10/87 to 7/13/95 42 West Locust Street 7/13/95 to Present Mary Michele Lindsey Mary Michele Lindsey The Mother of the child, is the Plaintiff, Mary Michele Lindsey, who currently resides at 42 West Locust Street, Mechanicsburg, Cumberland COunty, Pennsylvania, 17055. The Mother is single. The Father of the child, is the Defendant, Robert Lee Truax, Jr., who currently resides at 2766 Rock Creek Parkway North, Cordova, Tennessee, 38018. The Father is single. 7. The relationship of the Defendant, Robert Lee Truax, Jr., to the child is that of natural Father. The Defendant, currently resides with the fOllowing persons: ~ RELATIONSHIP Mr. Truax Father of Defendant Mrs. Truax Mother of Defendant The relationship of the Plaintiff, Mary Michele Lindsey, to the child is that of natural Mother. The Plaintiff currently resides with the following persons: ~ Bobbie Michelle Truax RELATIONSHIP Daughter The Plaintiff does not know of a person not a party to the proceedings who has physical custody of the child or claims to have custody or visitation rights with respect to the child. 8. The best interests and permanent welfare of the child will be served by granting the relief requested because: (a) Plaintiff is able to provide a loving and secure family environment for the child; (b) Plaintiff is able to provide proper care and supervision for the child; (c) Plaintiff is able to provide a safe, proper physical environment for the child; IN THE CIRCurr COURT OF TENNESSEE FOR THE THIRTIETH JUmCIAL CIRCutI' AT MEMPHIS MARY MICHELE (MEKAl TRUAX, plaintiff, v No. l078l2-2 RD .flW':? 1n</G. J J../ jJ('/cJ< /3.Y /.71 L..-CL.. IJ - / ~ -,y 7 FINAL DECREE OF DIVORCE ROBERT LEE TRUAX, JR., Defendant. This calEB came to be heam before the Honorabl- Charls3 McPherson, Judge of the Circuit court of Shelby County, Tennessee, Division ]I on the 8th day of July, 1987, upon the Second Amended complaint of plaintiff, the Answer and Counter complaint of Defendant, the Dismissal of the Counter complaint of Defendant, the testimony of plaintiff, the Settlement Agreement executed by the parties, the statements of counsel for the respective p:u:ties, and the entire record from which, It satisfacta:ily appealS to t1r coUIt that iIreconci1ab1e differenCES have arisen between the parties and that these iIrecon,..""hle differenCES ~ the continuation of the marriage. It further appeaI5 that the parties have made an eqlli,""hle settlement of all child custodY, child support, and property rights between the parties by wJitten agreement. It further appeaI5 that the Plaintiff resided in Shelby county, Tennessee for 6 montls prier to filing the complaint in this cause, that the parties were macied in Shelby County, Tennessee, and that more than 90 days have e1ap;ed since the complaint fa:' Divorce has been filed. It further appeaI5 that personal service was had upon the Defendant. It further appeilrR that the parties are entil:1ed to an atsolute divorce CtI the grounds of iIrecor'<"'"hl,, differeno:s. rr lS THEREFORE, ORDERED, ADJUDGED AND DECREED that the bonds of matrimony heretofore existing betw~ the plaintiff, MARY MICHELE (MEKAl TRUAX, and the Defendant, ROBERT LEE TRUAX, JR., are hereby "h=nlllte1.y and fcrevet' dissolved and the plaintiff is awarded an atsolute divorce and the parties are restcced all the rights and p:i.vileges of unmacied persons. I rr JS FURTHER ORDERED, ADJUDGED, AND DECREED that plaintiff is heI:~ granted custody of the parties' miner child, Bobble Michelle Truax, and Defendant is granted visltation rights as set out in the Settlement Agreement executed by the parties, and that Defendant pay to plaintiff the sum of $l75.00 per month as child support for the said childl rr JS FURTHER ORDERED, ADJUDGED, AND DECREED that the p:vy<:LLy set:l:lement agreement entered into by and between the parties in this CBIIIe, shall beoome a part of this decree and is incorporated herein by referencel That the cost of this C8\1le shall be taxed against: the Defendant, fer whi.ctl let execution issue. APPROVED FOR ENTRY: cbhi -.i ~ /1d-; ~ A ttomey fa:' Defendant ,.....-.( . , . - '. . Date: -2- IN THE CIRCUIT COURT OF TENNESSEE FOR THE THIRTIETH JUDICIAL DISTRICT AT MEMPHIS MARY MICHELE (MEKA) TRUAX, PlalntICf and Counter-Defendant, v NO. 107812-2 R.D. ROBERT LEE TRUAX, JR., Defendant and Counter-Plaintiff. ORDER OF TEMPORARY CUSTODY This cause came to be heard on the 14th day of November, 1986 before the Honorable Charles McPherson, Judge of Division n of the Circuit Court of Shelby County, Tennessee upon the Second Amended Complaint of Mary Michele Truax, and the Counter-Complaint of Robert Lee Truax, Jr.. the testimony of the parties and their witnesses, the argument of Stanley H. Less, counsel for plalnUCf and counter- defendant, and of Charles Rich, counsel for defendant and counter-plaintiff, and the entire record from which It appears that Mary Michele Truax Is a fit and proper person to assume temporary custody of the parties minor child, Bobby Michelle Truax, and that It Is In the best Interest of the said child for temporary custody to be placed with Mary Michele Truax; It further appears to the Court that Mary Michele Truax and Robert Lee Truax, Jr. should be enjoined from leaving the jurisdiction of this Court with the minor child pending further orders of this Court; and, It further appears that Robert Lee Truax, Jr. Is entitled to reasonable visitation with the said minor child. IT IS THEREFORE ORDERED, ADJUDGED AND DECREED that temporary custody be and Is hereby awarded to Mary Michele Truax, and that Robert Lee Truax, Jr. be and is hereby granted reasonable visitation rights with the said minor child. IT IS FURTHER ORDERED, ADJUDGED AND DECREED that Mary Michele Truax and Robert Lee Truax, Jr. be and are hereby enjoined from removing the said child from the -!"."r . IN THE ClRCurr COURT OF TENNESSEE FOR THE THIRTIETH JUDICIAL ClRCurr AT MEMPHIS MARY MICHELE (MEKAI TRUAX, Plalntiff, l07B12-2 R.D. ~ n ~ moo JUl 8 1987 v. ROBERT LEE TRUAX, JR., Defendant. SBTTLBMBNT AGREBMBNr This agreement is entered into I:rj and between MARY MICHELE (MEKAI TRUAX, hereinafter refetred to a'> "plaintiff", and ROBERT LEE TRUAX, JR., hereinafter referred to a'> "defendant". WITNESSETH: WHEREAS, these parties were married on September l6, 1983, in Cordova, Shelby County, Tennessee and there have been born of this marriage one minor childl and WHEREAS, the parties are ~esent1y separated and the plaintiff has filed an action fer divorce in the Circuit Court of Shelby County, Tennessee, alleging that iIrecxln""1,,hl.. differences have arisen between the parties heretol and WHEREAS, the parties desire to enter into an agreement with regard to their respective rights and obligations arising out of their mari.tal relationship in an amicable and mutually acceptable manner, sudl that said divorce action shall prooeed uncontestedl and WHEREAS, the parties desire to make adequate and s"Ffi('i""t [XOVlsions I:rj wrl.tl:en agreement fer the custody and maintenance of the child born of this maoiage and for a fair and eqnltAhl.. settlement of the ~ Iights between the partiesl NOW, THEREFORE, in ronsideration d. the mutual (XOmise3, convenants, and undertaldn<]3 hereinafta' mere fully set forth and fa: other good and VAl""hl.. ronsideration, the parties agree a'> follows: l. Husband and wife both acknowledge that they have eadl received all the hoIEehold good> and personal property that be1on<]3 to him Ol' he: and said property being in L' .......I"" of one er the other party shall be divested out of the other party and title vested in the party now having pc",.~l"". 2. Wife agrees that husband is to own the 1'I7~ ~p Van, and ft:tJM~ 8$Ume all indel::tedness, if any, thereon, and full title is herel:rj divested from wife and full. title is vested in hU'3band. HlSband agrees that wife is to own the Iq~11o.pk automobile, and~lkll$ume aU inde!ltednet:e, if any, thereon, and full. title is hereby divested from husband and full. title is vested in wife. 3. The parties agree to equally divide aU deI:ts, if any, which are cunently outstanding which were incurred from the date of the maniage, untU July l8, 1986, the date of the filing of the original Complaint for DivorC2 in this calSe, and further the parties agree to pay their own debts incurred individually after July l8, 1986. 4. The wife is hereby granted custody of the minor d1ild of this mac:iage namely, Bobble Michelle Truax. However, the husbarxl is granted visitati.al rlghbl on the fiIst and third Friday of rNerY month at 6:30 PM untU 8:30 PM on the following Sunday, exoe~ as noted below, and in aNlIHnIl, visitation as fallows: al From 6:00 PM on the second Frlday in June untU 6:00 PM on the fourth Friday in June of eadl year (however an. other weekend3 in June shaD. be with plaintiffh bl From 6:00 PM on the fiIst Frlday of August untU 6:00 PM on the third Frlday in August of eadl year (however an. other weekend3 in August shaD. be with plaint:iffl; cl From 9:00 AM on ThUISday, Thanksgiving moming, untU 6:30 PM on the next Friday, on oGi numbel" yeatS only; dl From 9:00 AM untU 6:30 PM on Easter Sunday, on even numbered yeaIS only; el From 9:0D AM untU 6:30 PM on July 4th on oGi numbered yeaIS only; gl From 9:00 AM until 6:30 PM on Labor Day on even numbered yeatS only; hI On odd numbered yeaIS, from 9:00 AM on December 25th untU 6:30 PM on December 30th, and on even numbered yeaIS, from 6:00 PM on Decembel" 25th until 6:30 PM on December 30th; 11 On odd numbered yeaIS, from 2:DO PM until 6:30 PM on the minor child's tirthday, July lath, and on even numbered yeaIS, from 9:00 AM until. 2:00 PM on July lath, so long lIS the d1ild is not in school. and husband shall be granted reasonable aCQe$ to the said d1ild on her birthday if she is in school. 5. Husband is to pay $l75.00 per month d1ild wpport for the d1ild until she d1ild ~ l8 yeaIS of~ge to br p-r& 1/.. Ot'\ IflT cF "",."f(; dM~ ~ ~ /6tlic( ft1~ f'Jl. ~9J(I). 6. Hii9ba"J{d and w e agree to equally divide all Court cxst:s arlslng em d this act:ion and eadl party agrees to pay his or her own attorney's fees. STATE OF TENNESSEE} SIII".J1Y CUUNTY SS I, JIMMY MOORE NINE DIVISIONS OF TIlE Clerk of the Circuit Court of said county, in the state aforesaid, do therein, named, in which PlaintiCC and ROBERT LEE TRUAX,JR Defendants as the SIUll<! appears of record and on file in my office, In testimony whereof I hereunto subscribe my name and affix the seal of said Court at offiice in tile city of Memphis this 5TH a of \. WillCH 19 97 ~J 1Y;ItHi/ C1"k STATE OF TENNESSEE} SIIEI.BY COUNTY JAMES RUSSELL I, sole and presiding Judge of the nIVISION 'mO OF '!HE Circuit Court of said County, do hereby certify that JImi MOORE whose genuine signature appears to the foregoing Certificate, is now, and WIIS at the time of signing the same, Clerk of said Court, and that his attestation is In due form, and by the proper officer, and that said Court is a Court of Record and that full faith and credit are due to all his official acts, Witness my hand and private seal (having no seal of office) , this the 5TH day of MARCH 1997 0-. ?~ Judge. Elc, (SEAL) STATE OF TENNESSEE} SIIELBY COUNTY JIMM'l MOORE I, , Clerk of the NINE DIVISIONS OF TIlE Circuit Court of said County, do hereby certify that JAMES RUSSELL whose gl'nuiole official siRnalure appears to the ahove and hereunto annexed Certificate is. and \I'll' al 1I11' time of siRning the same, sole and presiding J -, f tl DIVISION TWO OF '!HE C" C . I fl' uuRe 0 Ie _____ IrclIIt ourt III al\( or lIe County and Slate aforesaId, duly commission and qualified, and thaI all his ofrjcial IwL, as such art' entilled to full failh and credit, the day of . \J1-0J 1!tJl~ 19 97 CLERK ... .~~..-_.._-----~----_.. , * Mor'jH,c.hele LirldS.e,( Plaintiff : IN 'l'HE COUR'l' OF COMMON PLEAS OF :CUHBERLAND COUN'l'Y, PENNSYLVANIA . . * Qd:x:'r+ V Lee... Iruax) Jr, Defendant :CIVIL AC'l'ION - LAW ~NO. IL.\O \ CIVIL :CUS'l'ODY /VISI-'l'A'l'ION 19Q, '. ORDER OF COURT AND NOW, this (date) S \ \c...\lq" upon consideration of the attached complaint, it is hereby directed that the parti~s and their respective counsel ap.~ear before t::o.\,..$\~' ~v E'q. liCC, the conciliator, at 1B I.. I. _0\1\ __\\-. \v\@Olic ..:.~ on the 1M. day of .)~l-;:;:~' ,19 l ' at ::1 ~ ()(") P. Mo', for a Prehearing Custody Conference. At such conference, an, effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard 'by the court, and to enter into a temporazy order. Either party may bring the child who is the subject of this custody action to the conference, but the child/children's attendance is not mandatozy. Failure to appear 'at the conference 'may provide grounds for entzy of a tempqrazy or permanent order. FOR 'l'HE COUR'l': BY:~/~~inW1~~~~' YOU SHOULD 'l'AKE 'l'HIS PAPER 'I'D YOUR LAWYER A'l' ONCE. IF YOU DO NO'l' HAVE A LAWYER OR CANNO'l' AFFORD ONE, GO 'I'D OR 'l'ELEPHONE 'l'HE OFFICE SE'l' FOR'l'H BELOW 'l'O FIND OU'l' WHERE YOU CAN GE'l' LEGAL HELP. OFFICE OF 'l'HE COUR'l' ADHINIS'l'RA'l'OR COUR'l'HOUSE, FOUR'l'H FLOOR CARLISLE PA 17013 (717)240-6200 . ~~13a97 To Whom It May Concern: Regarding Bobbie Michelle Truax and her parents Mary Michele (Meka Interiano Truax) Lindsey and Robert Lee Truax Jr. in what has been labeled by someone as Case Number 97-l40l Civil Term in the Court of Common Pleas of Cumberland County, Pennsylvania, the following represents what some may label as an appeal of an Order of Court dated 28th day of April, 1997: 1. I am a victim in this situation and Mary is not. Mary did not let me have any visitstion time at all during the past Christmas-New Year season from December 23, 1996, until January 2, 1997, as she agreed to do less than a year ago on May 22, 1996, in the Agreement effective June l, 1996. In the Agreement effective June 1, 1996, agreed to by Mary and me in May 1996 I was granted visitation rights amounting to at least eighty-seven (87) days annually with a minimum of seventy-seven (77) days in the months of June, July, and August described in the Agreement as being "From 4:00 PM on the first Friday in June of each year until 6:00 PM on the fourth Friday in August of each year" and ten (10) days in the months of December and January described in the Agreement as being "From 10:00 AM on December 23rd of each year until lO:OO AM on January 2nd of the following year". However it was not until I had arrived in Harrisburg from Memphis by bus on December 23, 1996, that Mary told me she was not going to let our daughter Bobbie be with me at all this past Christmas. Therefore Mary owes me the $289.00 cost for the bus trip I would not have taken to pick up Bobbie if I had known Mary was not going to let Bobbie visit me. Attached is a copy of the bus ticket I bought on December 22, 1996. Mary also owes me ten (10) days visitation time with Bobbie as reparation for the ten (10) days visitation time with Bobbie that Mary did not let me hsve this past Christmas-New Year season from December 23, 1996, until January 2, 1997. 2. I am still being victimized. In all three of my correspondences to the Custody Conciliator Dawn S. Sunday I stated that I do not understand a Prehearing Custody Conference in 1997, thst Mary has custody of Bobbie and has had custody of Bobbie since before the Settlement Agreement in 1987, that I do not understand the mention of an attached complaint for in fact there was no complaint attached to the Order of Court dated 20th of March 1997, and that however if ever I am allowed custody of Bobbie I will accept custody of Bobbie. Yet in the Order of Court dated 20th of March 1997 it is stated that all children age five or older shall also be present at the conference--a conference for which I let the Custody Conciliator know in my correspondence sent to her on April l6, 1997, that I expected to be at the Veterans Administration Medical Center in Memphis, Tennessee, on April 22, 1997, and unavailable for inclusion in a telephone conference on April 22, 1997, beginning at 9:00 AM EDT. In paragraph 2. of the Custody Conciliation Summary Report my daughter Bobbie who is twelve is not listed as one of the individusls in attendance. If in fact Bobbie was not present at the conference that is an injustice against Bobbie for it is my understanding from Bobbie that she would rather I her father have primary physical custody of her instead of Mary her mother. In addition whether face-to-face, over telephone lines, or by way of written correspondence it is extremely difficult for Mary and me to reach a mutual agreement about anything especially any change relsted to visitation as exampled by the fact that the Agreement which became effective June 1, 1996, is the fruition of a process which began on August 4, 1995. To put it succintly I am against reducing numerically the annual minimum of eighty-seven (87) days visitation time within the months of June, July, August, December, and January I am authorized by the Agreement effective June I, 1996. In fact the annual minimum of eighty-seven (87) days visitation time within the months of June, July, August, December, and Janusry I am authorized by the Agreement effective June l, 1996, should be increased to eighty-nine (89) days within the months of June, July, August, December, and January to make up for the ten (10) days visitation time with Bobbie that Mary did not let me have this past Christmas-New Year season from December 23, 1996, until January 2, 1997. 3. I am being set up for more victimization. Mary moves our daughter Bobbie from Tennessee to Pennsylvania necessitating a change in the visitation schedule agreed to by Mary and me in 1987. In less than a year Mary flagrantly violates the visitation schedule she and I agreed to be effective June 1, 1996. Such action by a parent is an extremely bad example for a child. For a parent to do what he or she wants to do simply because he or she wants to do it is inappropriate parenting. Mary does not let Bobbie 1 2 visit me at all this past Christmas-New Year season from December 23, 1996, until January 2, 1997, and so what happens? Mary seeks to have the visitation schedule changed so that she appears to be in a correct position. Our daughter Bobbie has been at her mother's residence every Christmas Eve and every Christmas Day since 1986. The year 1996 was to have been the year when Bobbie started being at my residence every Christmas Eve and every Christmas Day and only six Christmas Eves and six Christmas Days at that until Bobbie turns eighteen. Mary and I signed the Agreement effective June 1, 1996, authorizing our daughter Bobbie to be with me from December 23rd of each year until January 2nd of the following year. I was to have hsd Bobbie with me at my residence this pust Christmas Eve and Christmas Day. Mary however committed an injustice ugainst both Bobbie and me by not letting me have visitation. The Agreement effective June 1, 1996, authorizes me to have Bobbie with me at my residence for the next five Christmas Eves and the next five Christmas Days as well as the next five New Year's Eves and the next five New Year's Days. I am opposed to relinquishing any part of that authorization. I contend that the Mother's proposed modifications to the existing Agreement which became effective June 1, 1996, as stated in paragraph 4. of the Custody Conciliation Summary Report substantially conflict with the Father's position in that the proposed modifications approximately reduce the Father's visitation rights an average of fourteen (14) days (one week on the front end of summer school vacation and one week on the back end of summer school vacation) in odd numbered years and seventeen (17) days (one week on the front end of summer school vacation, one week on the back end of summer school vacation, and three days on the front end of winter school recess including Christmas Eve and Christmas Day) in even numbered years. I also contend that confrontation is being built into the exercising of visitation rights if specific days and times are not stated for each and every occasion for which Bobbie is to be picked up or returned as done in both the Settlement Agreement entered on July 10, 1987 (not 1997 as stated in paragraph 3. of the Custody Conciliation Summary Report) and the Agreement effective June 1, 1996. I further contend that specific consequences need to be stipulated within an Order regarding violations of the visitation schedule established by said Order because Mary flagrantly violated the visitation schedule of the Agreement effective June 1, 1996, when she did not let me have the ten (10) days visitation time with Bobbie this past Christmas-New Year season from December 23, 1996, until January 2, 1997. 4. In keeping with the annual minimum of eighty-seven (B7) days visitation time within the months of June, July, August, December, and January I am authorized by the Agreement effective June 1, 1996, and in keeping with the use of specific days and times for each and every occasion for which Bobbie is to be picked up or returned as done in both the Settlement Agreement entered on July 10, 19B7, and the Agreement effective June 1, 1996, and including reparation for the ten (10) days visitation time with Bobbie that Mary did not let me have this past Christmas-New Year season from December 23, 1996, until January 2, 1997, and in consideration to avoid interference with the school schedule, and to avoid misunderstandings of what is a correct position and what is not, and because Bobbie has told me that sometimes her mother opens Bobbie's mail, and because Bobbie has told me that she has not received certain mail that I have sent her, and because I write Bobbie every Saturday that I am not with her, and because I have received only one letter from Bobbie this year, and because I am not being kept informed as to Bobbie's school activities, and as reimbursement for the $289.00 for the bus trip I would not have taken to pick up Bobbie this past Christmas-New Year season if I had known Mary wss not going to let Bobbie visit me, I am opposed to any change that does not authorize me an annual minimum of eighty-nine (89) days visitation time within the months of June, July, August, December, and January (that's an annual minimum of eighty-seven days within the months of June, July, August, December, and January authorized by the Agreement effective June 1, 1996, plus two days a year more within the months of June, July, August, December, and January for the five calendar years of 1997, 199B, 1999, 2000, 2001 as reparation for the ten days visitation time with Bobbie that Mary did not let me hsve this past Christmas-New Year season from December 23, 1996, until January 2, 1997) including each of the next five Christmas Eves and each of the next five Christmas Days and each of the next five New Yesr's Eves and each of the next five New Year's Days, that does not state specific days and times for esch and every occasion for which Bobbie is to be picked up or returned as done in both the Settlement Agreement entered on July 10, 1987, and the Agreement effective June 1, 1996, that does not state specific consequences to be 3 imposed upon Mary if she does not relinquish physical custody of Bobbie to me when she is supposed to do so, that does not forbid Mary to open or censor or withhold any mail I send to Bobbie, that does not insure that Mary has Bobbie write and mail me a letter every Saturday that I am not with her, that does not insure that Mary will keep me informed of Bobbie's school activities, and that does not reimburse me $289.00 for the bus trip I would not have taken to pick up Bobbie this past Christmas-New Year season if I had known Mary was not going to let Bobbie visit me. 5. To achieve partially that which is stated in paragraph 4. above I suggest that the following replace the content of paragraphs 3. and 4. of the Order of Court dated 28th day of April, 1997: A. The Father shall have partial physical custody of the Child during the summer school vacation in every year beginning at 4:00 PM on the last day of the school year and ending at 6:00 PM on the day before school resumes in the Fall. Notwithstanding the foregoing, in 1997, the Father shall have custody of the Child beginning at 4:00 PM on June 6, 1997. B. The Father shall have partial physical custody of the Child during the winter school recess beginning at 4:00 PM on the last day of class before the Christmas-New Year holiday break and ending at 6:00 PM on the day before school resumes in January. C. A violation by the Mother to relinquish physical custody of the Child to the Father when the Mother is supposed to do so as depicted in paragraphs A. and B. above will immediately and permanently terminate the authorization for the Mother to have primary physical custody of the Child while simu1tsneous1y establishing for perpetuity the authorization for the Father to have primary physical custody of the Child. 6. To achieve further that which is stated in paragraph 4. above I suggest that the following be included in the Order of Court dated 28th day of April, 1997: A. The Mother is forbidden to open or censor or withhold any mail the Father sends to the Child. B. The Mother will see to it that the Child writes and mails the Father a letter every Saturday that the Mother has custody of the Child. C. The Mother will see to it that the Father receives a yearly copy of the school handbook-calendar as well as copies of all the Child's report cards, attendance records, teachers' names, class schedules, standardized test scores, and other school records and/or information to which the Mother has access. D. The Mother is to pay the Father $289.00 in cash at 4:00 PM on June 6, 1997, as reimbursement for the bus ticket he bought on December 22, 1996. 7. Because it is understood that the Mother and the Father do not get along to say the least I suggest that the following also be included in the Order of Court dated 28th day of April, 1997: A. The definition of 'a responsible adult' as to any provision of this Order is hereby expressly limited to these three persons: the Mother, the Father, and the Father's Father. B. The Father's Father may pick up and/or return the Child in behalf of the Mother or the Father. 8. Because the Mother moved the Child from Tennessee to Pennsylvania and because not to do so would probably be unconscionable I suggest that all cost involved for purposes of exchanges of custody be somewhat specifically equally disbursed between the Mother and the Father by replacing the last sentence of paragraph 5. of the Order of Court dated 28th day of April, 1997, with the following: Notwithstanding anything else in this Order, beginning in June 1997 the Mother and the Father are to share all cost involved for purposes of 4 exchanges of custody. This is to be achieved by the parent who is to receive custody of the Child taking sole care of the financial cost in picking up the Child at the residence of the parent who is to relinquish custody of the Child, by the parent who is to receive custody of the Child takinR sole care of the financial cost in transportinR the Child away from the residence of the parent who is to relinquish custody of the Child, and by the parent who is to receive custody of the Child taking sole care of the financial cost in transporting the Child back to her or his residence. In conclusion I say this: I honestly believe it will really be better for Bobbie if I the Father have primary physical custody of Bobbie the Child instead of Mary the Mother. For one thing unlike being under Mary's parental supervision in which Bobbie has been and still is a latch-key child under my parental supervision Bobbie has never been a latch-key child nor will she ever likely be. For another thing unlike Mary's commendable educational achievement of having received a high school diploma my commendable educational achievement of having gone beyond a high school diploma to receive a master's degree seemingly makes me more qualified than Mary to help Bobbie ac&demically during the learning period she will be embarking on when she is thirteen and enters eighth grade this Fall. Additionally Bobbie has stated she wants to be an ordained minister. I am an ordained minister and Mary is not. Vocationally speaking I provide the role model Bobbie can follow into the ordained ministry and Mary does not. Furthermore it is my understanding from Bobbie that she would rather I her father have primary physical custody of her instead of Mary her mother. Again I say: if ever I am allowed custody of Bobbie I will accept custody of Bobbie. IN WITNESS WHEREOF, I set my signature below. !id~~k Sworn to and subscribed MY COMMISSION EXPIRES: My CommiSSion Exoires '.2J 2900 , , , .. .~...~~.~-~.~....~~.~._._..\~ I . I .,...,. t .. . ... . . "., ',. .~. "" c. , ,...... t_, jot i) L- J r'lt c. .:. ~ 1 fit..... '~ ""rrHnnrr r\nl/rr'!',... AI: 1',,'\11 IH'~l':. .....'... . lh....,t~:..'! ~'. ~..t L"!~ , ',i... t[.i.U\" l"II".OCI-,T I:. .;,.!. . ~I.l.. . . .. ..1_ .. ...... - - . . ..~..~:. ...-- .. -. .. EiP1RES: e6Jail97 h .. ,f;:'u~o""u II~:"..::: j'U:"':": -r:;tJUU';'~.~ '-, .. ~; ) I.. 'I'~ I ! f 1,1 t: . " '.../ MARY MICHELE LINDSEY, . IN THE COURT OF a:lMMON PLEAS OF . Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA . . . vs. . NO. 97-1401 CIVIL TERM . . . ROBERT LEE TRUAX, JR., : Defendant . IN CUSTODY . au>BR OF CXXIRT AND tOI, this , <;. l\., day of 16. -..' I , consideration of the attac'lie'dcustody Con~ and directed as follows: 1997, upon is ordered 1. The Mother, Mary Michele Lindsey, and the Father, Robert Lee Truax, Jr., shall have shared legal custody of Bobbie Michelle Truax, born July 18, 1984. 2. The Mother shall have primary physical custody of the Child. 3. The Father shall have partial physical custody of the Child during the sumner school vacation in every year beginning one full week after the last day of the school year and ending one full week before school resumes in the Fall. Notwi thstanding the foregoing, in 1997, the Father shall have custody of the Child beginning on June 6 at the end of the school day in an effort to make up for the period of Christmas holiday custody which the Father was not permitted to exercise in 1996. 4. The parties shall share or alternate custody of the Child on holidays as follows: A. Christmas: In odd numbered years, the Father shall have custody of the Child over the Christmas holiday from Decentler 23 until the day before school resumes. In even numbered years, the Father shall have custody from DecelliJer 26 until the day before school resumes. B. Thanksgiving/SEring Break: In every year, the Father shall be entitled to have custody of the Child either for the Child's entire Thanksgiving vacation from school or Spring break from school upon providing thirty (30) days advance notice to the Mother. 5. For purposes of exchanges of custody under this Order, when the Child is to be transported to and from the Father's residence in Tennessee by car, the Father shall pick up the Child from the Mother's residence and return the Child to the Mother's residence. When transportation of the Child is to be provided by bus, the Mother shall transport the Child to the Harrisburg bus station at the beginning of the Father's period of custody and shall pick up the Child from the Harrisburg bus station at the end of the Father's period of custody. When the Child is to be transported to and from the Father's residence by airplane, the MARY MICHELE LINDSEY, Plaintiff IN THE COURT OF a:lMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 97-1401 CIVIL TERM . . ROBERT LEE TRUAX, JR., Defendant . . : IN CUSTODY aJS'lOOY CXH:ILIATlOO SlIIlARY REPCRT IN ACXXlUlANCB wrm <UmBRLAND CXDmt' RIlLE OF CIVIL PRO KlI\JRE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRl'IJ CIlRRIlNTLY IN ammy OF Bobbie Michelle Truax July 18, 1984 Plaintiff/Mother 2. A Conciliation Conference was held on April 22, 1997 with the following individuals in attendance: The Mother, Mary Michele Lindsey and her counsel, Susan K. Candiello, Esquire. The Father, Robert Lee Truax, Jr., who resides in Tennessee, did not attend the Conference. The Conciliator contacted the Father's residence three times by telephone and left messages on the answering machine inquiring as to whether the Father would like to participate in the Conciliation Conference by telephone or whether he would like a continuance of the Conference until June 6, 1997 when he would be in Pennsylvania to pick up the Child for a period of custody. The Father wrote several letters in response to the Conciliator's inquiries, first advising that he would be available to participate in the Conference by telephone and then indicating on the day before the scheduled Conference that he would not be available by telephone. The Father made no request to have the Conference continued to June 6, 1997. 3. A prior Custody Order was entered on July 10, 1997 by the Court in Tennessee based on the parties written Agreement settling all matters related to their divorce. The Mother moved to CuIliJerland County, Pennsylvania in 1995 and the parties entered into a written amended CUstody Agreement effective June 1, 1996. The amended Agreement provides for the Mother to have primary custody of the Child with the Father to have partial custody of the Child during the sumner school vacation and over the Christmas vacations from DecelliJer 23 until January 2. 4. The Mother filed this Complaint for CUstody requesting a modification of the parties' prior Agreement to provide that the Mother i ~ " , @.bEe 0 5 1997 To Thomas E. Cheffins the Court ndministrator at One Courthouse Square, Carlisle, Pennsylvania 17013, Mary Michele (Meka Interiano Truax) Lindsey the Mother of Bobbie Michelle Truax at 42 West Locust Street, Mechanicsburg, pennsylvania 17055/ and Whomever Else It May Concern. ~ Regarding the Child Bobbie Michelle Truax who was born in Shelby County, Tennessee, on July 10, 1904, and her parents Mary Michele Lindsey and Robert Lee Truax Jr. in Case Number 97-1401 Civil Term in the Court of Common Pleas of Cumberland County, pennsylvania, the following facts are put forth. 1. For each and every month since February 1987 through and including October 1997, the Father Robert Lee Truax Jr. has paid $175.00 child support for his daughter Bobbie Michelle Truax. In support of that fact Robert has in his possession either canceled checks or other receipts for all J'lnymant:!l marlO? 2. Contrary to a visitation right granted the Father Robert Lee Truax Jr. in an Amendment Agreement signed by both the Mother Mary Michele (Meka Interiano Truax) Lindsey and the Father Robert Lee Truax Jr. in May 1996 and effective June 1, 1996, which states in part that the Father Robert Lee Truax Jr. is to have visitation with his daughter Bobbie Michelle Truax "From 10100 AM on December 23rd of each year until 10100 AM on January 2nd of the following year," the M~ther Mary Michele Lindsey did no!: let the child Bobbie Michelle Truax visit her father Robert Lee Truax Jr. at all on Christmas Day 1996 or at any time from 10100 nM on December 23, 1996, until 10.00 AM on January 2, 1997. Robert had even written Mary on November 1, 1996, and again on November 15, 1996, reminding her that he was to be at the HarriSburg Greyhound Bus Station at 10100 AM on December 23, 1996, for her to deliver Bobbie to him for visitation time beginning then and ending at 10100 AM on January 2, 1997. Robert stapled each note respectively to the checks for chi~d support dated November 1, 1996, and November 15, 1996, which he mailed and Mary cashed. Robert had also written Mary on December 1, 1996, and again on December 15, 1996, reminding her that he was to be at the Harrisburg Greyhound Bus Station at 10:00 AM on December 23, 1996, for her to deliver Bobbie to him for visitation time beginning then and ending at 10100 AM on Januarl' 2, 1997. Robert stapled each of those two notes respectively to the checks for child support dated December 1, 1996, and December 15, 1996, which he mailed and Mary cashed. However, it was not until after Robert had bought a $289.00 bus ticket on December 22, 1996, and had arrived in HarriSburg from Memph~s by bus on December 23, 1996, that Mary told Robert that she was not go~ng to let Bobbie visit him. Mary therefore owed Robert restitution for the $289.00 bus ticket bought on December 22, 1996. 3. For the month of November 1997, the $175.00 child support for the Chi~d'Bobbie Michelle Truax to be paid by her father Robert Lee Truax Jr. ~nderwent an offset of $87.50--$87.50 being the balance owed the Father Robert Mee Tru~,Jr. by the Mother Mary Michele Lindsey as restitution for the $289.00 bus, ticket bought on December 22, 1996--an item for which Bobbie in ?eh~lf of Mary has given Robert $201.50 in total prior to November 1997. 4. Contrary to a visitation right and exchange of custody granted the Father Robert Lee Truax Jr. in an Order of Court in the Court of Common Pleas of CUmberland County, pennsylvania, dated 28th day of April, 1997, which states in part that "In every year, the Father shall be entitled to have custody of the Child either for the Child's entire Thanksgiving vacation from schpol or spring break from school upon providing thirty (30) days advance notice to the Mother" and for which the Father Robert Lee Truax Jr. wrote the ~ther Mary Michele Lindsey on October 2, 1997, and again on October 14, 1997, letting her know that he wanted to have custody of their daughter Bobbie Michelle Truax for Bobbie's entire Thanksgiving vacation from school beginning on November 26, 1997, and also for which Robert called Mary on October 26, 1997, letting her know that he wanted to have custody of Bobbie for Bobbie's entire Thanksgiving vacation from school beginning on November 26, 1997, the Mother Mary Michele Lindsey did not let the Child Bobbie Michelle Truax visit ~er father Robert Lee Truax Jr. at all on Thanksgiving Day 1997 or at any time during Bobbie's entire Thanksgiving vacation from school--a five-day period of time from November 26, 1997, through December 1, 1997. Mary therefore owes Robert restitution for the five (5) days visitation time Mary did not let Rpbert have from November 26, 1997, through December 1, 1997. 5. For the month of December 1997, the $175.00 child support for the Child Bobbie Michelle Truax to be paid by her father Robert Lee Truax Jr. 1 .. , ,"')'::" r:7r:'f.'/'.. o' .. I,. ~, 1'1 ,~ 1_".. i..... .',. I~.', .' -, i,;,,'" 'elf: . ~ ~!,' r:"'-r'Trt...; . "...,. l,'.. ,,~, . ""',< I..., ... 'vnl P:r ;;: 11I1 ..J.....'IY ", . . , ~ 2 underwent an offset of $125.00--$125.00 being the amount determined to be the restitutional financial equivalent of the five (5) days visitation time the Mother Mary Michele Lindsey did not let the Father Robert Lee Truax Jr. have from November 26, 1997, through December 1, 1997, according to the following: a. The total dollar amount of child support payments to be made by Robert from September 1, 1997, through nugust 31, 1998, was to have been twenty-one hundred dollars. b, The total number of days visitation time authorized Robert by the Order of Court in the Court of Conunon Pleas of cumbedand County, pennsylvania, dated 28th day of npril, 1997, from September 1, 1997, through nugust 31, 1998, in eighty-four (84)--the eighty-four (84) days being comprised of the five (5) days from November 26, 1997, through December 1, 1997, pluB the twelve (12) days from December 23, 1997, through January 4, 1998, plus the sixty-seven (67) days from June 11, 1998, through nugust 17, 1998. c. The total number of days visitation time Mary did not let Robert have from November 26, 1997, through December 1, 1997, was five (5). d. Twenty-one hundred dollars divided by eighty-four times five is one hundred twenty-five dollars. Beginning on December 20, 1997, all future child support payments for the Child Bobbie Michelle Truax to be paid by her father Robert Lee Truax Jr. including child support payments which undergo offsets because the Mother Mary Michele Lindsey fails to comply in letting the Child Bobbie Michelle Truax visit her father Robert Lee Truax Jr. as provided by and in accordance with the Order of Court in the Court of Common Pleas of cumberland County, pennsylvania, dated 28th day of npril, 1997, will be p,lid only if and when and after the Mother Mary Michele Lindsey delivers the Child Bobbie Michelle Truax into the care of her father Robert Lee Truax Jr. for the purpose of exchange of custody and visitation as provided by and in accordance with the Order of Court in the COurt of Common Pleas of cumberland County, pennsylvania, dated 28th, day of npril, 1997. The next date upon which the Mother Mary Michele Lindsey is to deliver the Child Bobbie Michelle Truax into the care of her father Robert Lee Truax Jr. for the purpose of exchange of custody and visitation as provided by and in ~ccordance with the Order of Court in the Court of Conunon Pleas of Cumberland County, pennsylvania, dated 28th day of npril, 1997, is December 23, 1,997. If the Father Robert Lee Truax Jr. neither arrives by car at 42 West Locust Street, Mechanicsburg, Pennsylvania 17055, by 4:00 PM on December 23, 1997, in order to facilitate his having custody of his daughter Bobbie Miche1,le Truax, nor calls from the Harrisburg Greyhound Bus station by 4100 PM on December 23, 1997, in order to facilitate his having custody of his daughter 'Bobbie Michelle '.l'ruax, then the ~lother Mary Michele Lindsey is to transport the ChHd Bobbie Michelle Truax to the Harrisburg nirport and put Bobbie on an airplane leaving Harrisburg for Memphis on December 23, 1997, for the purpose of exchange of custody and visitation as provided by and in accordance with the Order of Court in the Court of Common Pleas of Cumberland County, Pennsylvania, dated 28th day of npril, 1997. Failure by Mary to facilitate Bobbie visiting Robert will result in a cessation of child support payments. IN WITNESS WHEREOF, Robert Lee Truax Jr. sets his signature below. W~~ ROBERT LEE '.l'RUAX R ~~ 1- J~~^J DnTE I \\\\I"UUIl""/~ ,\\ \\!;Il.fl " m~'~~~...J;n...~~, day of ......" I' ::r:"C'-': ~,_ " ',.L\ " .... -J,' '( ..,~-;. 5~'/ l \1.' .... .. S:J; : ~ ~l. : . ! NOTARY B ICi.. E ~ l$I\ \J\\\(;~."'" J \ ..t,'" ......\ $ ~.,~ "" ,'... ~ '" 11)............1'\ ~.. -''''1' '( f'l.\\ ~,\' "1.-"1:",.:,\,\\\1\\\ , 1997. Sworn to and subscribed before MY COMMISSION EXPIRES: 3'27~20C)J ;1.1 l~,\, ! 'II I I . I I I , I \ ( II ! \ II \ \ \ \ \ , I I 1 I i I i I I I ,/'7,"" I ;.1 t+"\ ~ oJ 0:1 ~:L '1) , " . L. ' ..J.::J.../ U I I ~ q:llo I Cl_ I ~ ~ . :>- l'C) l~ ~ ~~ xa:." \' <t: ~ &I) ~ \at ~.\t~ . ~< \~~ ~ \...l ~ l U - p-~ ~ I ~.o g ,<0.0<< ,Q <:" Q l~c-cU I'f) - C ..... - \.u~ V)qC~~ <C)~~ Li: l- ~ " u.<t:'V)>- ~~\.u~ :I:~V)~ u - '::) ~ ~ 0 Q;; lli-~ t: I- \..... Q~\.U V)<!:',::>-J <t: 0 V) ~I-u_ QQ::\U~ ~~<.q;: ......UO\"J N N .... ,') , ~\ ... o r. ... .., .~ MARY MICHELE LINDSEY, . IN THE COURT OF COOMON PLEAS . Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA . : vs. . NO. 97-1401 CIVIL TERM . . . ROBERT LEE TRUAX, JR., . CIVIL ACTION - LAW . Defendant . IN CUSTODY . ~' ~ au>BR OF CXXIRT AND tOI, this 12th day of June, 1997, the Conciliator, having received no cOll1Ounication from the Petitioner-Father, who failed to appear for the scheduled CUstody Conciliation Conference, hereby relinquishes jurisdiction in this case. (C~~lJ~~~ Dawn S. Sunday, Esquire CUstody Conciliator ~ (1' ~ ~ ...: ...... '6 .. ?~!; u.J -1' C"l 0" c...)"'"'. .- L)~} tF.~) .- {~~ .('- c.. ~b r" :'(~l tl: - ., :..' u.Jc- ft:Z re\-~~ % \.~.aJJ \" ::::> C10- -- -, .' 1.\. r;; ? 0 0 'f~ - 1'+0 I c'.;..:.k. T..",,~ Nove.mber /3 1991 J ~ klhoM ][1i I1QY COhcer~: R~ra;~ Bobhie M:c.helle. Tr-UQ1., MJ hel'lqre.nt.s nll"Y /1;Jele. Lintey o.J Rotert Lee 'frLlQ}I. Jr.. in Cq.se JVvmber ~1-I~OI Lv:! TerlYJ ;h He COUl't ot- Com~Oh flell.5 ot Cvmbe"IAnJ Covn+y ff-ht\sl/van:a ~h~ h/;+h r-esfect to qh Drier ot COIlr-t;1\ He COIlt-t of CO/nIl'lOh fl:lts ot (1IIl1be:lClhJ County fe.nn'ylvllh;Q ~Q teJ 2Hh ~ay ot Apr; I) 19~1,) which ill fctr+ .stqies: '11'1 evel-l yeQ~ the Fo.Het s~411 ~e e.ht+le.~ -to halle. w.stoJy of the Ch:lJ ei-l-her tor the. Ch;\~'.s eh+;..e T~qh~?jll;~ lIltCa+:oh tro~ SGhobl or sl",;, ~reak iI-om ,Sc,hool vfoh frDVi~.:~9. fhi..+, (3D~~~y.s ClaVQnCe ho+'c.e -h> the f/ofherJ QrlJ klh;ch tVr+~el' 6tQ te.s' W'heh He CUJ /5 to be tl'ah5Aor+e~ to allJ -trOIn f~e. Fll.+hel-~ t-e.s iJet'lc.e by qit-f \q~eJ +he. f1J~(,1' .shall e"oVi~e. tr-QhsfOl'ta'koh for He Ch,'IJ to IlhJ f1.om He. o.irfort ih Harrisbu:y, He n;l~ InVIf+ ie qcto~ClhjJ by q 'r-~fon.sj ble qJlIlt Jeh trQlIelir~ hy ~1J5 Or Q;rflqne -lir q~ e(chl1~e of clIstoJy. He- rlofhe.l' ~'r-ees -to e1v~lll shQre +he C.06+ o-t +he (h;l~s t'OVhJ !J-t'f qjrt-Q.l'e. ~... exc.hQ~e.s at c.v5+04y, RoLe.rt lee Truax. Jr., wrote Ma"y f1;c1ele Li,,1er On Oc.to!el- Z l~q1 ql"{ R9qih oh Dc-toter 14 1~~1 It!.tf."j, he!' Khow that I klCUJ +0 hQv~ :usfoJy of BOhbie f1.-che lie. Tru~x fo~ 8oUie.s en+;t-e. nah~~:v;ns lAl.Cll-t;Oh tt"Ot'tt sdool !fj;h~j~i 01'1 tJeclne.sJCl.Y Nove/l'ltel' Zl, 1~~1. r 0.150 cqllJ f'/q,t-y oh Oc+obe~ Z~ 1'191 Ie.tt.hj he,. knolv HrJ I \Vall +0 have. c.V$~Jy o~ 80bb"e -tor ADbt.'e '.s :h+:t-e.) Thllh.ksJ:vihj VQCqf:oh fi.o/l'l sc.hool t~: I\llihf( Ot} hJeJhe-sJQY /lJolleJ\'l1e.t- Z~J 199'1. I ho,ve C.Ok+,t-IrlJ hI:th 9obbie. Hqt .s~e. is both willihj qnJ ~reeahle. 10 flY:hj -h.,tn Hc~l'ris~:1 to f'letyhis ro... nQ/I~~qiv:~ C1\'1J ~~.Cljh 'hI' (hl'i.stma.s, I hqve, let Loth Mo.t-y Rh~ AoL!ie KhOW +hilt 1"w;1I fl'ck lJf 'Bobb,'€. at +he Me.lYlfh,'s qil'fOl't at nQhksJjVi~ -hme. QhJ ~flit\ qt Ckt'isttrlQ5 title, tJhqt I heeJ 10 know tl"o"" Mitt-X ;s Ll/ott whQt qj"/:he. 8Dbbie. hod I Le Qt'r;lIj~y) VfDVI wk(:J tl1ht hlJlnbtt' Botb,'e hi; II te. ql-l'illi~,) QhJ ctt what 1-;h1e. 8~H,'e. .,,:11 be Q.......'1Jjtu. .L ,lI....u (, C~,M.s t4f' 11,!'Y 11:..~t/e.l.l"JSH (J I J L L f 7' cOfies To' COll~+ Al...:.i4t...~W. f1atj,t~ .t M~;t M:'~llIe rM/Q,); "obet- T ee. ~~ -I tj Olle Ctu~"I..u&e ~II4l'(. '17, ""est La~-st shut ~'l~' Ro./liCH&t\ t'Kwv.N. CQ,~I:s'c. I't"",yl~;Q /7013 MeC.t.....:CJAIIlJ, '~_hlyllltlh;1/ /70.55 c.~JWq, Te-all, 3/JD18 . Mor'1~' L\r'\dSe.'l Plaintiff : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY, : PENNSYLVANIA v. . Ro~c:r \- L.\ruo')<., .J!, Defendant : CIVIL ACTION LAW ;NO.I~D\ CIVILI9Q-, : CUSTODY VISITATION ORDER OF COURT And now, this ll.l.=:llS.B, upon consideration of the attached complaint, it is hereby directed that ,?e above pw:'~es and ~ective coun~el appear befo~~~~ ~5\.t"\rb-.f-' EsqUire, the concilIator, at . H,Q\r"\ "I,-, \v\~ ch ( , Pennsylvania, on the II day of R-~ )rl;.........~ ,1998, at \ \: Or) ~ P.M., for a Pre-hearing Custody Conference. At such confere ce, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may be present at the conference. Failure to appear at the conference may provide grounds for the enlIy of a temporary or pennanent order. FOR THE COURT: By: ~(\\~'~~1I~. Custody Conciliator ('t\:)~ YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. THE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE,PA 17013 (717) 249-3166 1-800-990-9108 . ~ , JAN 1 2 1998 " To the Honorable Court of Common Pleas of Cumberland County, Pennsylvania c/o Thomas E. Cheffins, Court Administrator One Courthouse Square, ,Carlisle, Pennsylvania 17013 Reqarding Case Number 97-1401 Civil Term, and your Order of Court dated 28th day of April, 1997, relative to Case Number 97-1401 Civil Term, and the Amendment Agreement siqned by both Mary Michele (Meka Interiano Truax) Lindsey the Mother of the Child 80bbie Michelle Truax and Robert Lee Truax Jr. the Father of the Child 80bbie Michelle Truax in May 1996 and effective June 1, 1996, which preceded your Order of Court: Whereas, contrary to a visitation right granted the Father Robert Lee Truax Jr. in the Amendment Agreement which states in part that the Father Robert Lee Truax Jr. is to have visitation with his daughter Bobbie Michelle Truax "From 10,00 AM on December 23rd of each year until 10:00 AM on January 2nd of the following year," the Mother Mary Michele Lindsey did not let the Child Bobbie Michelle Truax visit her father Robert Lee Truax Jr. at all on Christmas Day 1996 or at any time from 10,00 AM on December 23, 1996, until 10:00 AM on January 2, 1997--a ten-day period of time. Robert had even written Mary on November 1, 1996, and again on November 15, 1996, and again on December 1, 1996, and again on December 15, 1996, reminding Mary that he was to be at the Harrisburg Greyhound Bus station at 10:00 AM on December 23, 1996, for her to deliver Bobbie to him for visitation time beginning then and ending at 10:00 AM on January 2, 1997. Robert stapled each note respectively to the checks for child support dated November 1, 1996, and November 15, 1996, and December 1, 1996, and December 15, 1996, which he mailed and Mary cashed. HOWever, it was not until after Robert had bought a $289.00 bus ticket on December 22, 1996, and had arrived in HarriSburg from Memphis by bus on December 23, 1996, that Mary told Robert that she was not going to let Bobbie villit hlJll1 and Whereas, contrary to a visitation right and exc:hange of custody granted the Father Robert Lee Truax Jr. in your Order of Court which states in part that "In every year, the Father shall be entitled to have custody of the Chi~d either for the Child's entire Thanksgiving vacation from school or spring break from school upon providing thirty (30) days advance notice to the Mother" and for which the Father Robert Lee Truax Jr. wrote the Mother Mary Michele Lindsey on October 2, 1997, and again on October 14, 1997, letting her know that he wanted to have custody of their daughter Bobbie Michelle Truax for'Bobbie"s entire Thanksgiving vacation from school beginning on November 26, 1997, and also for which Robert called Mary on October 26, 1997, letting her know that he wanted to have custody of Bobbie for Bobbie's entire Thanksgiving vacation from school beginning on November 26, 1997, the Mother Mary Michele Lindsey did not let the Child Bobbie Michelle Truax visit her father Robert Le.e ';l'ruax Jr. at all on Thanksgiving Day 1997 or at any time during Bobbie's entire Thanksgiving vacation from school--a five-day period of time from November 26, 1997, through December 1, 1997; and Whereas, contrary to a visitation right and exchange of custody granted the Father Robert Lee Truax Jr. in your Order of Court which states in part that "In odd numbered years, the Father shall have custody of the Child over the Christmas holiday from December 23 until the day before school resumes", the Mother Mary Michele Lindsey did not let the Child Bobbie Michelle Truax visit her father Robert Lee Truax Jr. at any time during the Christmas holiday--a twelve-day period of time from December 23, 1997, through January 4, 1998; I the Father Robert Lee Truax Jr. do hereby petition you to cite the Mother Mary Michele (Meka Interiano Truax) Lindsey for contempt of Court; and I the Father Robert Lee Truax Jr. do hereby petition you to qrant me primary physical custody of the Child Bobbie Michelle Truax effective immediately; and I the Father Robert Lee Truax Jr. do hereby petition you to require the Mother Mary Michele (Meka Interiano Truax) Lindsey to pay monthly child support in the amount of $175.00 on the first day of each month by means of a United States Postal Service money order made out to the Child Bobbie Michelle Truax for $175.00 effective immediately; and I the Father Robert Lee Truax Jr. do hereby petition you to grant the Mother Mary Michele (Meka Interiano Truax) Lindsey partial physical custody of 1 . . ~ , ... 2 the Child Bobbie Michelle Truax for the following periods of time with the provision that all partial physical custody is to be conducted within a five- mile radius of my residence: a. From 5:00 PM to 7:00 PM every February 17 (the Mother's birthday), and b. From 1:00 PM to 7:00 PM every Easter Sunday I and c. From 9:00 AM to 7:00 PM every Mother's DaYI and d. From 7:00 PM on July 4 (Independence Day) to 7:00 PM on July IB (the Child's birthday); and e. From 1:00 PM to 7:00 PM every Thanksgiving DaYI and f. From 7:00 PM on December 25 (Christmas Day) to 7:00 PM on December 31 (New Year's Eve). IN WITNESS WHEREOF, Robert Lee Truax Jr. sets his signature below. ~k~~ ROBERT LEE TRUAX R(J M g, J~q8 Sworn to and subscribed before , 199B. N \i z '" c:::J j; I- .... en .,........,00 ~ ...... '-' 1'00 a:~~ai-i :vt If!,DQ ......0 v; {"'i' ~g :i ~ 'I 1\\\ ~ , I I I I I \ I \ I I ! I I i I \ \ \ ~ gco I ~ I :><0 I .!i:;: f~~~ i- ~ Po 00 l~l~ 1 B M~. 'tl~~ tl$~ ~~s !:! ., .... ~ ~ ~ Po . i o u I 5g ~J 000 ~I i~ UU . r..oo ~ iil~ uu 00 ~wi~~ l!l OPo ~~iS . go~~ OlI:O 00 lI:E-<UH ~~~~ '" ~ o r- ~ >- ~Q ~~ l.4J\J) M C;X::\U :r <'.::) If' lT1 q::Ql' lT1 :;:)I.u lT1 1-< If' UJ r- nJ QC N - . - (II o (II (II I'l It 1 f'I .. o ... .. ,~ .. .4 ' · \ To Thomas E. Cheffins the Court Administrator at One Courthouse Square, Carlisle, Pennsylvania 17013; Mary Michele (Meka Interiano Truax) Lindsey the Mother of Bobbie Michelle Truax at 42 West Locust Street, Mechanicsburg, Pennsylvania 17055; and Whomever Else It May Concern: Regarding the Child Bobbie Michelle Truax who was born in Shelby County, Tennessee, on July 18, 1984, and her pnrents Mary Michele Lindsey and Robert Lee Truax Jr. in Csse Number 97-1401 Civil Term in the Court of Common Pleas of Cumberland County, Pennsylvanis, the following is a reminder: Contrsry to a visitation right and exchange of custody granted the Father Robert Lee Truax Jr. in an Order of Court in the Court of Common Pleas of Cumberland County, Pennsylvania, dated 28th day of April, 1997, which states in part that "In odd numbered years, the Father shall have custody of the Child over the Christmas holiday from December 23 until the day before school resumes", the Mother Mary Michele Lindsey did not let the Child Bobbie Michelle Truax visit her father Robert Lee Truax Jr. at any time during the Christmas holiday from December 23, 1997, through January 4, 1998. Mary therefore owed Robert restitution for the twelve (12) days visitation time Mary did not let Robert have from December 23, 1997, through January 4, 1998. For the months of Janusry 1998 and February 1998, the combined three hundred fifty (350) dollars child support for the Child Bobbie Michelle Truax to be paid by her father Robert Lee Truax Jr. underwent an offset of three hundred (300) dollars--three hundred (300) dollars being the amount determined to be the restitutional financial equivalent of the twelve (12) days visitation time the Mother Mary Michele Lindsey did not let the Father Robert Lee Truax Jr. have from December 23, 1997, through January 4, 1998, according to the following: a. The total dollar amount of child support payments to be made by Robert from September 1, 1997, through August 31, 1998, was to have been twenty-one hundred dollars. b. The total number of days visitation time authorized Robert from September 1, 1997, through AuguQt 31, 1998, is ei&hty-four (84)--th& eighty-four (84) days being comprised of the five (5) days from November 26, 1997, through December 1, 1997, plus the twelve (12) days from December 23, 1997, through January 4, 1998, plus the sixty-seven (67) days from June 11, 1998, through August 17, 1998. c. The total number of days visitstion time Mary did not let Robert have from December 23, 1997, through January 4, 1998, was twelve (12). d. Twenty-one hundred dollars divided by eighty-four times twelve is three hundred dollars. In conjunction with the statement made on December 2, 1997, that "Beginning on December 20, 1997, all future child support payments for the Child Bobbie Michelle Truax to be paid by her father Robert Lee Truax Jr. including child support payments which undergo offsets because the Mother Mary Michele Lindsey fails to comply in letting the Child Bobbie Michelle Truax visit her father Robert Lee Truax Jr. as provided by and in accordance with the Order of Court in the Court of Common Pleas of Cumberland County, Pennsylvania, dsted 28th day of April, 1997, will be paid only if and when and after the Mother Mary Michele Lindsey delivers the Child Bobbie Michelle Truax into the care of her father Robert Lee Truax Jr. for the purpose of exchange of custody and visitation as prOVided by and in accordance with the Order of Court in the Court of Common Pleas of Cumberland County, Pennsylvania, dated 28th day of April, 1997," a payment of the remaining combined fifty (50) dollars child support for the months of January 1998 and February 1998 as well as any payments of child support for the months beyond February 1998 will be paid only if and when and after the Mother Mary Michele Lindsey delivers the Child Bobbie Michelle Truax into the care of her father Robert Lee Truax Jr. for the purpose of exchange of custody and visitation as provided by and in accordance with the Order of Court in the Court of Common Pleas of Cumberlsnd County, Pennsylvania, dated 28th day of April, 1997. The next date upon which the Mother Mary Michele Lindsey is to deliver the Child Bobbie Michelle Truax into the care of her father Robert Lee Truax Jr. for the purpose of exchange of custody and visitation aa provided by and in accordance with the Order of Court in the Court of Common Pleas of 1 MARY MICHELE LINDSEY, . IN THE COURT OF COMMON PLEAS OF . Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA : vs. . NO. 97-1401 CIVIL TERM . CIVIL ACTION - LAW ROBERT LEE TRUAX, JR., . . Defendant . IN CUSTODY . au>BR OF a:xJRT AND tOI, this 2.~r..\ day of _Fe. b t ~~ ) , 1998, upon consideration of the attached CUstody conciliation Report, it is ordered and directed as follows: 1. The prior order of this Court dated April 28, 1997 shall continue in effect with the addition of the following provision. 2. In the event the Father intends to have the Child transported by airline to and fran Tennessee for an exchange of custody under this Court order, the Father shall advise the Mother thirty (30) days in advance of the period of custody and shall either obtain the necessary roundtrip plane tickets (for which the Mother shall reimburse the Father in the amount of one-half of the cost within thirty (30) days of receipt) or the Father shall forward to the Mother one-half of the cost of the roundtrip plane tickets so that the Mother may purchase the tickets. In the event the Father intends to transport the Child by car or bus for an exchange of custody under this Court's order, the Father shall provide two (2) weeks advance notice to the Mother of the specific date, time and place for the exchange. J. cc: Robert L. Truax, Jr. - Pro Sa Susan K. Candiello, Esquire - Counsel for Mother ~ ~ ~/:J.'f-lq8. ,..8,"6'. MARY MICHELE LINDSEY, . IN THE COURT OF COMMON PLEAS OF . plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA . . . vs. . NO. 97-1401 CIVIL TERM . . . ROBERT LEE TRUAX, JR., . CIVIL ACTION - LAW . Defendant . IN CUS'IODY . PRIOO JUDGE: J. Wesley Oler, Jr. CUS'laJY CXH:ILIATlOO stI!MARY Rmm IN ACCXIIDJ\NCE wrm aJoIBERLAND <XXNl'Y RULE OF CIVIL ~ oRr(JRE 1915.3-8, the undersigned CUstody Conciliator submits the following report: 1. '!he pertinent information concerning the child who is the subject of this litigation is as follows: NAME DATE OF BIRTB CllRRml'Ly IN CUS'lOOY OF Bobbie Michelle Truax July 18, 1984 Mother 2. A Conciliation Conference was held on February 17, 1998, with the Mother, Mary Michele Lindsey in attendance. Although the Mother was not accompanied by counsel at the Conference, she is represented in this matter by Susan K. candiello, Esquire. The Father, Robert Lee Truax, Jr., who resides in Tennessee, did not attend the Conference, and did not contact the Conciliator to make arrangements to participate by telephone. 3. The Father filed this Petition Pro Sa indicating that the Mother did not permit the Child to have her period of partial custody with the Father over the Christmas holiday in 1997 as provided for in this Court's prior order dated April 28, 1997. The Father did not request a finding of contempt or modification of the existing order, but instead demanded "restitution" and an offset in child support for the missed period of partial custody. Also in his Petition, the Father requested that for the next exchange of custody in June, the Mother await either the Father's appearance at her home or a telephone call from the bus station by 4:00 p.m. and, if the Mother has not heard from the Father by 4:00 p.m., she is to make airline arrangements for the Child to fly to Memphis, Tennessee on the same day. 4. The Mother explained in response to the Father's concerns (as expressed in the Petition, a copy of which is attached to this Report) that the Father has not been willing to work with her concerning making arrangements for exchanges of custody. According to the Mother, the Father sent a note to the Mother prior to the Thanksgiving break advising that he would pick up the Child at the bus station. Subsequently, the Mother stated she received a letter from the Father asking her to put the Child on an airplane and have the Child call the Father when she arrives in Tennessee. The Mother stated that she not comply with the Father's request " ! I 'I I I i 1 02-~3-199B 15:21 71l 2'100402 (;U\IUlIiLAI<IU I.UUt< I >lUll WEB '13 1998 . ..--;-- To'Thomal E. ChlffinG the Court Admini.trator at One courthou.. squar., Carlilll, Penn.ylvania 17013: Mary Michale (Keka Interiano Truax) L!nda.y the Mother of Bobbie Michelle Truax at 42 We.t Locu.t 8treet, Mechanic.bura, Penn.ylv.ni. 170551 .nd Whom.ver El.. It Hay Conc.rnl R.S.rdina the Child Bobbie Michelle Tru.x who w.. born in Shelby County, T.nn....., on July 18, 1984. and h.r parent. Hary Michele LindllY .nd Robert Lee Truax Jr. in Ca.e Number 97-1401 Civil Term in the Court of COmMon PleoG of Cumb.rland County, penn.ylv.nia, the followinB i. a reminders Contrary to a Visitation riSht .nd exchllnge of cu.tady granted the Fllther Robert Leo Truax Jr. in nn Order of Court in tbe Court of COlll1lon Plau of Cumb.rland County, Ponn.ylv.nia, dat.d 28th d.y of April, 1997, wbich .t.t.. in p.rt that "In odd numb orad yeare. the Father eh.ll bave cu.tady of the Child over the Chriltmu ho11dey from Dac.lIlber 23 until the day before ochool r..ume.", the Mother Mary Micbele Lindsey did not let the Child Bobbie Mich.lle Tru.x visit b.r flther Robart Lee Truax Jr. at Iny ti~e during the Cbri.tma. holidey from D.cember 23, 1997, through Jenuary 4, 1998, Mary tb.r.for. owed Robert r..titution for the twelve (12) days visitation time Mary did not let Robert h.vo from Decembsr 23, 1997, through January 4. 1998. For the munths of Jenunry 1998 and February 1998, the combined three hundred (ifty (350) dollers child support for the Child Bobbie Hichelle Truax to be paid by her father Robert Lee Truax Jr. underwent an offsat of three hundred (300) dollare--three hundred (300) dollare beins tbe amount determined to be the reetitutionsl finenc1a1 equivalent of the twelve (12) l1ays v1eitation time the Mother Mary Michele Lindsey did not let the pather Robert Lee Truax Jr. have from December 23, 1997, through January 4, 1998, according to the following I e. The total doller amount of child eupport psyment. to be made by Robert from September 1, 1997, throuBh AUBust 31, 1998, W81 to have been twenty-one hundr.d dollar.. b, The total number of days visitation time authorized Robert from September 1, 1997, throuBh August 31, 1998, i. eighty-four (84)--the eighty-four (84) days being comprisld of the fivI (5) day' from November 26, 1997, through December 1, 1997, plus the twelve (12) day. from necember 23, 1997, through January 4. 1998, plul the .ixty-seven (67) day. from June 11, 1998, through August 17, 1998. ' c. The total number of days vieitation time Mary did not let Robert have from December 23, 1997, through January 4, 1998, was twelve (12). d. Twenty-one hundred dollars divide~ by eighty-four timea twelve 1. three hundred dol111re, In conjunction with the statement msde on December 2, 1997, that "Beginning on December 20, 1997, all future child support payments for the Child Bobbie Michelle Truax to be paid by her father Robert Lee Tru.x Jr. includina child support payments which undergo offset. because the Mother Mary Kichal. Lindeey fails to comply in let tins the Child Bobbie Michelle Truex vieit her fethar Robert Loe Truax Jr. as pravi~ed by and in accordance with the Order of Court in the Court of Common Pleae of Cumberland County, Pannlylvanls, dated 28th day of April, 1991, will be paid only if and when and aftllt the Mother Hary Michale Lindsey deliverB the Child Bobbie Michelle Truax into the cat I of her father Robert Lee Truax Jr. for the purpo.e of .xchange of eUlltody Ind visitation as providad by and in accordance with the Ord.r of Court in the Court of Co~on Pleas of Oumb.rl.nd County, Pennsylvani., dated 28th day of April, 1997," a payment of the remainin! combined fifty (50) dollar. child eupport for the months of January 1998 and February 1998 as well es any pS)'1lIents of child support for the months beyond F.bruary 1998 will be paid only if and when and aftar the Mother Mary Michele Lindsey deliver a tha Child Bobbie Michelle Truax into the care ef her fether Robart Lee Trusx Jr. for the purpose of exchauge of custudy and vie1tation as provided by and in accordance with the Order of Court in the Court of COmMon Plell8 of Cumberland County, Penn.ylv.nia, dsted 28th day of April, 1997. The next date upon which the Mother Mary Michele Lindley ia to deliver the Child Bobbia Michelle Truax into tha care of Iler father Robert Lee Truax Jr. for the purpose of exchense of cu.tody and visitation as provided by and in occurdance with the Order of Court in the Court of COlllllon Ple.. of 1 ,..-. ~MAR 09 1998 . To Thomas E. Cheffin!l the Court ndministrator at One Courthouse Square, Carlisle, pennsylvania 17013; Hary Michele (Heka Interiano Truax) Lindsey the Mother of Bobbio Michelle 'rruax at 42 West Locust Street, Mechanicsburg, penn!1ylvania 17055; and Whomever Else It May Concern: Regarding the Cldid Bobbie Hichelle 'rruax who was born in Shelby County, Tennessee, on ,JlIly lB, 19B4, and her parents Mary Michele Lindsey and Robert Lee Truax Jr. ill Case Number 97-1401 Civil Term in the Court of Common Pleas of Cumberland County, pennsylvania, the following is a reminder: Contrary t:o a lIisitatJ.on right and exchange of custody granted the Father Robert Lee Truax Jr. in an Order of Court in the Court of Common Pleas of Cumberland County, Pennsylvania, dated 28th day of npril, 1997, which states in part that "In odd numbered years, the Father shall have custody of the Child ov\!r the Chr,btman holiday frem Dcccmb.,r 23 until the day Leforc school resumes", the 110ther Mary Hichele Lindsey did not let the Child Bobbie Michelle Truax visit her father Robert Lee Truax Jr. at any time during the Christmas holiday from December 23, 1997, through'January 4, 1998. Mary therefore owed Robert restitution for the twelve (12) days visitation time Mary did not let Robert have from ()ecember 23, 1997, through January 4, 1998. For the months of January 1998 and February 1998, the combined $350.00 child support for the Child Bobbie Michelle Truax to be paid by her father Robert Lee Truax Jr. underwent an offset of $300.00--$300.00 being the amount determined to be the restitutional financial equivalent of the twelve (12) days visitation time the Mother Hary Michele Lindsey did not let the Father Robert Lee Truax Jr. have from ()ecember 23, 1997, through January 4, 1998, according to the following: a. The total dollar amount of child support payments to be made by Robert from september 1, 1997, through nugust 31, 1998, was to have been twenty-one hundred dollars. b. The total number of days visitation time authorized Robert from september 1, 1997, through August 31, 1998, is eighty-four (84)--the eighty-four (84) days lJelny comprised of the five (5) days from November 26, 1997, through December 1, 1997, plus the twelve (12) days from December 23, 1997, through January 4, 1998, plus the sixty-seven (67) days from June 11, 1998, through nugust 1/, 1998. c. The total number of days visitation time Mary did not let Robert have from December 23, 1997, through January 4, 1998, was twelve (12). d. Twenty-one hundred dollars divided by eighty-four times twelve is three hundred dollars. In conjunction with the statement made on December 2, 1997, that "Beginning on December 20, 1997, all future child support payments for the Child Bobbie Michelle Truax to be paid by her father Robert Lee Truax Jr. including child support payments which undergo offsets because the Mother Mary Michele Lindsey fails to comply in letting the Child Bobbie Michelle Truax visit her father Robert Lee Truax Jr. as provided by and in accordance with the Order of Court in the Court of Common Pleas of Cumberland County, Pennsylvania, dated 28th day of npril, 1997, will be paid only if and when and after the Mother Mary Michele Lindsey delivers the Child Bobbie Michelle Truax into the care of her father Robert Lee Truax Jr. for the purpose of exchange of custody and visitation as provided by and in accordance with the Order of Court in the Court of Common Pleas of Cumberland County, Pennsylvania, dated 28th day of April, 1997," a payment of the remaining combined $50.00 child support for the months of January 1998 and February 1998 as well as any payments of child support for the months beyond February 1998 will be paid only if and when and after the Mother Mary Michele Lindsey delivers the Child 80bbie Michelle Truax into the care of her father Robert Lee Truax Jr. for the purpose of exchange of custody and visitation as provided by and in accordance with the Order of Court in the Court of Common Pleas of Cumberland County, Pennsylvania, dated 28th day of npril, 1997. The next date l>pt)n which the Mother Mary Michele Lindsey is to deliver the Child Bobbie Michelle Truax into the care of her father Robert Lee Truax Jr. for the purpose 0: exchange of custody and visitation as provided by and in accordance with the Order of Court in the Court of Common Pleas of Cumberland County, pennsylvania, dated 28th day of npril, 1997, is June 11, 1 ., . i I . \ \ i i . . , . -., -, . . ( ~ 0, M ......:..:- ''" :"\ 'i / ,J f , . I \ . ! ! i I . . \ I ~ ~ '<Qo - . >- ~ c:II!~N) l-7w ~4l:~ ~~"I ~ "I ~loo!\iI ~~ ,\u 'lI: ~ ,\u t..I r- :-1 ~ , u - ,>- ~ ~ :~ 0 :~..oQ c:Q..D< ,0 C- 0 Q::I'(\.J ~ ~ - ~ V) - '< - ~ Q ~ <' - c:) - ~ r--. - ":::) - 4:) \u "' V qc - -~ ~ ~ V) ::s ~ <.C!1 I') rJ _v, 5:! .... U. I~ 1.1.. W ~ " W \I) 0 :t: ':) ~ l" u " Q P q..; llJ ~ \u- ":) . '. \J'l 0 -f ~ c,) ~ ~ -J 0 \u <a:: ~ "< <( 0 ~ ... ..... (; To Curtis R. Long the Prothonotary for the 1I0norable Court of Common Pleas of Cumberland County, pennsylvania c/o Richard J. Pierce, Court ndministrator One Courthouse Square, Carlisle, Pennsylvania 17013 Regarding Case Number 97-1401 Civil Term in the Court of Common Pleas of Cumberland County, Pennsylvania, in which Judge J. Wesley Oler Jr. has mnde previous rulings dated April 2B, 1997, and February 23, 199B: Whereas, contrary to Mary Michele (Meka Interiano Truax) Lindse,'s signed Verification dated February 21, 1997, of the Complaint for Custody Modification dated March 13, 1997, that she and Robert Lee Truax Jr. agreed that she and their minor child Bobbie Michelle Truax who was born in Shelby County, Tennessee, on July lB, 19B4, could leave the jurisdiction of the state of Tennessee in .July 1995, Mary Michele 1.lndsey and Robert Lee Truax Jr. never ever talked about such a thing let alone reach agreement on such a thing, for Robert Lee Truax Jr. would never ever agree that it is okay with him for his daughter Bobbie Michelle Truax to be hundreds of miles away from him/ and Whereas, Mary Michele Lindsey signed the Verification which states that the verification is made subject to the penalties of Pennsylvania law relating to unsworn falsification to authorities/ and Whereas, Robert Lee Truax Jr. is willing to accept primary physical custody of his daughter Bobbie Michelle Truax and to return his daughter Bobbie Michelle Truax to the jurisdiction of the state of Tennessee/ I Robert Lee Truax Jr. the Father of the Child Bobbie Michelle Truax do hereby petition the Honorable Court of Common Pleas of Cumber:and County, Pennsylvania to strike the judgments dated April 2B, 1997, and February 23, 199B, and to summarily grant me primary physical custody of the Child Bobbie Michelle Truax effective 4:00 PM EDST on Thursday June 11, 199Bl and I Robert Lee Truax Jr. the Father of the Child Bobbie Michelle Truax do hereby petition the Honorable Court of Common Pleas of Cumberland County, Pennsylvania, to instruct Mary Michele Lindsey the Mother of the Child Bobbie ~ichelle Truax to relinquish primnry physical custody of the Child Bobbie Michelle Truax to me at 4:00 PM EDST on Thursday June 11, 199B, at 42 West Locust Street, Mechanicsburg, Pennsylvania 17055/ and I Robert Lee Truax Jr. the Father of the Child Bobbie Michelle Truax do hereby petition the Honorable Court of Common Pleas of Cumberland County, Pennsylvania, to allow me to begin returning the Child Bobbie Michelle Truax by car to the jurisdiction of the state of Tennessee at 4:00 PM EDST on Thursday June 11, 199B/ and To the ends petitioned in the three paragraphs immediately preceding this paragraph, I Robert Lee Truax Jr. the Father of the Child Bobbie Michelle Truax do hereby recommend an Order in the form as attached. IN WITNESS WHEREOF, I Robert Lee Truax Jr. set my signature below. ~E~i:::tf Sworn t~~~~~scribed f..",~,......~~~ l (' :~:11 '~tllu\\\'\'7 MY ,COMMISSION EX'tii~'\I\'" ~ MY MIS ION EXf~nES 2_ 'lOM mJ 11 ICJ'l DATE 0,'." .. "", "', ,q~ '."'.' ""J2199B' '-AI ~~ .~. ~_ lIlO~BLIC '- ~ \,..0 1'\.;1, "" ~...'r~' ,)~. 1\' I ; '. "iJ.... ,,\ \!\ , ,,-\r ~ o. ~ ~ II': lJ~Q .. '3 - 0;% ~0 ..,... f-J....~ ':r.= 0: '-:l>"' ~Q ".;;.J c., :.=.;? ~o. N .:J..": C': -. u:UJ ~ ;?j"'u i!: o<t :c ~Jl: .;:: ~L 10 ;:, .., 'O"l () ... d ,Jt . , ,. '-f- ,----I . l "- ", < ~!. . , @ APR 1 3 1998 To Richard J. pierce the Court Administrator at One Courthouse Square, Carlisle, Pennsylvania 17013, Mary Michele (Meka Interiano Truax) Lindsey the Mother of Bobbie Michelle Truax at 42 West Locust Street, Mechanicsburg, Pennsylvania 17055/ and Whomever Else It May Concern. Regarding the Child Bobbie Michelle Truax who was born in Shelby county, Tennessee, on July IB, 19B4, and her parents Mary Michele Lindsey and Robert Lee Truax Jr. in Case Number 97-1401 Civil Term in the Court of Common Pleas of Cumberland County, Pennsylvania, in which Judge J. Wesley Oler Jr. has made rUlings dated April 2B, 1997, and February 23, 199B: This is notification to the Mother Mary Michele Lindsey that the Father Robert Lee Truax Jr. will arrive by car at 42 West Locust Street, Mechanicsburg, Pennsylvania 17055, by 4.00 PM EDST on Thursday June 1I, 199B, to receive physical custody of his daughter Bobbie Michelle Truax and to begin transporting the Child Bobbie Michelle Truax to the state of Tennessee. Contrary to a visitation right and exchange of custody granted the FatheL Robert Lee Truax Jr. in the Order of Court in the Court of Common Pleas of Cumberland County, Pennsylvania, dated 2Bth day of April, 1997, relative to Case Number 97-1401 civil Term in the Court of Common Pleas of Cumberland County, Pennsylvania, which in part states that "In odd numbered years, the Father shall have custody of the Child over the Christmas holiday from December 23 until the day before school resumes", the Mother Mary Michele Lindsey did not let the Child Bobbie Michelle Truax visit her father Robert Lee Truax Jr. at any time during the Christmas holiday from December 23, 1997, through January 4, 199B. The Mother Mary Michele Lindsey ther~fore owed the Father Robert Lee Truax Jr. restitution for the twelve (12) days visitation time the Mother Mary Michele Lindsey did not let the Father Robert Lee Truax Jr. have with the Child Bobbie Michelle Truax from December 23, 1997, through January 4, 1998. For the months of January 199B and February 199B, the combined $350.00 child Support for the Child Bobbie Michelle Truax to be paid by her father Robert Lee Truax Jr. underwent an offset of $300.00--$300.00 being the amount determined to be the restitutional financial equivalent of the twelve (12) days visitation time the Mother Mary Michele Lindsey did not let the Father Robert Lee Truax Jr. have with the Child Bobbie Michelle Truax from December 23, 1997, through January 4, 1998, according to the following: a. The total dollar amount of child support payments to be made by Robert from September 1, 1997, through August 31, 1998, was to have been twenty-one hundred dollars. b. The total number of days visitation time authorized Robert from September 1, 1997, through August 31, 1998, is eighty-four (84)--the eighty-four (84) days being comprised of the five (5) days from NOvember 26, 1997, through December 1, 1997, plus the twelve (12) days from December 23, 1997, through January 4, 1998, plus the sixty-seven (67) days from June 11, 199B, through ~ugust 17, 199B. c. The total number of days visitation time Mary did not let Robert have with Bobble from December 23, 1997, through January 4, 1998, was twelve (12). 1 .... i' " " ! ! . 2 d. Twenty-one hundred dollars divided by eighty-four times twelve is three hundred dollars. In conjunction with the statement made on December 2, 1997, that "Beginning on December 20, 1997, all future child support payments for the Child Bobbie Michelle Truax to be paid by her father Robert Lee Truax Jr. including child support payments which undergo offsets because the Mother Mary Michele Lindsey fails to comply in letting the child Bobbie Michelle Truax visit her father Robert Lee Truax Jr. ae provided by and in accordance with the Order of Court in the Court of Common Pleas of Cumberland county, Pennsylvania, dated 28th day of April, 1997, will be paid only if and when and after the Mother Mary Michele Lindsey delivers the Child Bobbie Michelle Truax into the care of her fa ther Rober!; Lee Truax Jr.", a payment of the remaining combined $50.00 child support for the months of January 1998 and February 1998 will be paid only if and when and after the Mother Mary Michele Lindsey delivers the Child Bobbie Michelle Truax into the care of her father Robert Lee Truax Jr. This is notification to the Mother Mary Michele Lindsey that the next time and place the Mother Mary Michele Lindsey is to deliver the child Bobbie Michelle Truax into the care of her father Robert Lee Truax Jr. is 4:00 PM EDST on Thursday June 11, 199B, at 42 West Locust Street, Mechanicsburg, Pennsylvania 17055. The Father Robert Lee Truax Jr. will arrive by car at 42 West Locust Street, Mechanicsburg, pennsylvania 17055, by 4.00 PM EDST on Thursday June 11, 199B, to receive physical custody of his daughter Bobbie Michelle Truax and to begin transporting the Child Bobbie Michelle Truax to the state of Tennessee. f'ailure by the Mother Mary Michelle Lindsey to facilitate the Father Robert Lee Truax Jr. receiving physical custody of the Child Bobbie Michelle Truax at 4.00 PM EDST on Thursday June 11, 199B. will result in a forfeiture of,child support payments. Savings bonds equivalent in value to child support payments for the Child Bobbie Michelle Truax (minus offsets of child support payments which undergo Offsets) which are forfeited by her Mother Mary Michele Lindsey and not paid by her father Robert Lee Truax Jr. will be purchased by him and set aside for him to give Bobbie after July IB, 2002 (her eighteenth birthday). IN WITNESS WHEREOF, Robert Lee Truax Jr. sets his signature below. ~E~!f::gf D~ 1) JqqJ' -/ r~ ('1m ,'Il Sworn to and subscribed before me this the _ day of L,.....1t , 199B. /(//yJ- IJ .1tJr NOTARY PUBLIC MY COl-l/olISS;OI-1 EX:>InE~. ~)-f(l - ~____ .. ~ \ (!JAY 0 5 1998 " . MARY MICHELE LINDSEY, Plaintiff IN TilE COURT m' Cmll-ION PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 97-1401 CIVIL TEml CIVIL ACTION - k\W ROBERT LEE TRUAX, JR. Defendant IN CUSTODY DliCLARATlON OF AI'~'IRMATlON AND REQUEST FOR A LAW ENFORCEMENT OFFICER AND NOW, this ~~ day of rf) consideration of 0 hearing scheduled for Wednesday, EDST, in Courtroom No.1, Cumberland County Courtho and in lieu of my physical presence at the hearing, Father of the Child Bobbie Michelle Truax do hereby , 1998, upon ay 27, 1998, at 2:00 PM se, Carlisle, Pennsylvania, I Robert Lee Truax Jr. the affirm the following: 1. Contrary to Mary Michele (Meka Interiano Truax) Lindsey's signed Verification doted February 21, 1997, of the Complaint for Custody Modification doted ~Iarch 13, 1997, that she and I Robert Lee Truax Jr. agreed that she and our minor child Bobbie Michelle Truax who was born in Shelby County, Tennessee, on July 18, 1984, could leave the jurisdiction of the state of Tennessee in July 1995, Mary Michele Lindsey and 1 Robert Lee Truax Jr. never ever talked about such 0 thing let alone reach agreement on such a thing, for I Robert Lee Truax Jr. would never ever agree that it is okay with me for my daughter Bobbie Michelle Truax to be hundreds of miles away from me. 2. Mary Michele (Meka Interiano Truax) Lindsey signed the Verification which states that the verification is mode subject to the penalties of Pennsylvsnia law relating to unsworn falsification to authorities. 3. 1 Robert Lee Truax Jr. the Father of the Child Bobbie Michelle Truax am willing to accept primary physical custody of my daughter Bobbie Michelle Truax and to return my daughter Bobbie Michelle Truax to the jurisdiction of the state of Tennessee. 4. I Robert Lee Trusx Jr. the Father of the Child Bobbie Michelle Truax petitioned the Honorable Court of Common Pleas of Cumberland County, Pennsylvania, on March 19, 1998, to strike the judgments doted April 28, 1997, and February 23, 1998, snd to summarily grant me primary physical custody of the Child Bobbie Michelle Truax effective 4:00 PM EDST on Thursday June 11, 1998. 5. I Robert Lee Truax Jr. the Father of the Child Bobbie Michelle Truax petitioned the Honorable Court of Common Pleas of Cumberland County, Pennsylvania, on March 19, 1998, to instruct Mary Michele (Meka Interiano Truax) Lindsey the Mother of the Child Bobbie Michelle Truax to relinquish primary physical custody of the Child Bobbie Michelle Truax to me Robert Lee Trusx Jr. the Father of the Child Bobbie Michelle Truax at 4:00 PM EDST on Thursday June II, 1998, at 42 West Locust Street, Mechanicsburg, Pennsylvania 17055. 6. 1 Robert Lee Truax Jr. the Father of the Child Bobbie Michelle Truax petitioned the Honorable Court of Common Pleas of Cumberland County, Pennsylvania, on Msrch 19, 1998, to allow me Robert Lee Truax Jr. the Father of the Child Bobbie Michelle Truax to begin returning the Child Bobbie Michelle Truax by car to the jurisdiction of the state of Tennessee at 4:00 PM EDST on Thursday June II, 1998. 7. I Robert Lee Truax Jr. the Father of the Child Bobbie Michelle Truax notified Mary Michele (Meka Interiano Truax) Lindsey the Mother of the Child Bobbie Michelle Truax on April 7, 1998, that I Robert Lee Truax Jr. the Father of the Child Bobbie Michelle Truax would arrive by car at 42 West Locust Street, Mechanicsburg, Pennsylvania 17055, by 4:00 PM EDST on Thursday June II, 1998, to receive physical custody of my daughter Bobbie Michelle Truax and to begin transporting the Child Bobbie Michelle Truax to the state of Tennessee. AND WHEREAS, 1 Robert Lee Truax Jr. the Father of the Child Bobbie 1 it . , > 2 Michelle Truax reccived mail from Mary Michele (Meka Interiano Truax) Lindsey which is postmarked April 23, 1998, and which states in part "don't waste your time coming up in June", and which is signed "Mary M. Meka"; AND WHEREAS, I Robert Lee Truax Jr. the Father of the Child Bobbie Michelle Truax consider it appears to have bcen a waste of my time to have gone to rllceive physical custody of my daughter Bobbie Michelle Truax only on the occasions when in fact Mary Michele (Meka Interiano Truax) Lindsey the Mother of the Child Bobbie Michelle Truax did not let me Robert Lee Truax Jr. the Father of the Child Bobbie Michelle Truax have physical custody of my daughter Bobbic Michelle Truax as exampled in December 1996 when I bought a $289.00 bus ticket in Memphis, Tennessee, on December 22, 1996, and arrived by bus at the Harrisburg Greyhound Bus Station in Harrisburll, Pennsylvania, on December 23, 1996, at which time 1 was to receive physical custody of Bobbie from Msry but at which time Mary told me that she was not going to let Bobbie visit me at all from December 23, 1996, throullh January 2, 1997; I Robert Lee Truax Jr. the Father of the Child Bobbie Michelle Truax do hereby request the Honorable Court of Common Pleas of Cumberland County, Pennsylvania, to have a law enforcement officer present at 42 West Locust Street, Mechanicsburg, Pennsylvania 17055, by 4:00 PM EDST on Thursday June II, 1998, in order to facilitate the exchange of physical custody of the Child Bobbie Michelle Truax from Mary Michele (Meka Interiano Trusx) Lindsey the Mother of the Child Bobbie Michelle Truax to me Robert Lee Truax Jr. the Father of the Child Bobbie Michelle Truax at 4:00 PM EDST on Thursday June II, 1998. IN WITNESS WHEREOF, I Robert Lee Truax Jr. set my signature below. , Ro~hF:::tJ DATE fi1tJ- I) /~qJ> Sworn to and subscribed before me this the ~ MY COMMISSION EXPIRES: Vf COMMIllSlOM EXPIRES ^UO. 111. 19~ copy and stamped envelope enclosed for: Susan Kay Candiello, Esquire Suite 100 1013 Mumma Road Lemoyne, PA 17043 Counsel for the Mother >- co r; 9; c:: 1- .. ;;)_.... II J~1' ,~ r.) :~'. 0,. U;lt ~J;;.: 11__. ... ".~ ::i Cii_- , . of;; 1...)1', -> '"I" ,'12-: li:' . ,....., ":;;j . ~Ip ~', ..~, ".!u. -, :.r~: .:-": 1,- "''l :,) U 0' U -...-;. \ .: .' > ~ ~ r, '-\' .,' I,,; ;. . ., ~UffiY MICHELE LINDSEY, Plaintiff IN THE COURT OF CO~MON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 97-1401 CIVIL TERfI CIVIL ACTION - LAW ROBERT LEE TRUAX, JR. Defendant IN CUSTODY OFFICIAL NOTIFICATION OF SPECIFIC DATE, TUIE, AND PLACE FOR THE EXCIIANGE OF CUSTODY AND NOW, this ~ day of , 1998, upon consideration of my providing at least two (2) we advance notice to Mary Michele (Meka Interiano Truax) Lindsey the Mother f the Child Bobbie Michelle Trusx that I Robert Lee Truax Jr. the Father of the Child Bobbie Michelle Truax intend to transport the Child Bobbie Michelle Truax by car relative to my receiving physical custody of the Child Bobbie Michelle Truax, I Robert Lee Truax Jr. the Father of the Child Bobbie Michelle Truax do hereby submit the following: 1. I Robert Lee Truax Jr. the Father of the Child Bobbie Michelle Truax will arrive by car on Thursday June II, 1998, by 4:00 PM EDST at 42 West Locust Street, Mechanicsburg, Pennsylvania 17055, to receive physical custody of my daughter Bobbie Michelle Truax from her mother Mary Michele (Meka Interiano Truax) Lindsey and to begin transporting my daughter Bobbie Michelle Truax to the state of Tennessee. 2. I Robert Lee Truax Jr. the Father of the Child Bobbie Michelle Truax requested the Honorable Court of Common Pleas of Cumberland County, Pennsylvania, on May I, 1998, to have a law enforcement officer present on Thursday June 11, 1998, by 4:00 PM EDST at 42 West Locust Street, Mechanicsburg, Pennsylvania 17055, in order to facilitate the exchange of physical custody of my daughter Bobbie Michelle Truax from her mother Mary Michele (Meka Interiano Truax) Lindsey to me. 3. Be it known the specific date for the exchange of custody is Thursday June 11, 1998. 4. Be it known the specific time for the exchange of custody is 4:00 PM Eastern Daylight Savings Time. 5. Be it known the specific place for the exchange of custody is the front stoop at 42 West Locust Street, Mechanicsburg, Pennsylvania 17055. AND WHEREAS, for each and every month since February 1987 through and including October 1997, I Robert Lee Truax Jr. the Father of the Child Bobbie Michelle Truax have paid $175.00 child support for my daughter Bobbie Michelle Truax; AND WHEREAS, I Robert Lee Truax Jr. the Father of the Child Bobbie Michelle Truax have in my possession either canceled checks or other receipts for all child support payments made by me for my daughter Bobbie Michelle Truax from February 1987 through and including October 1997; AND WHEREAS, for the month of November 1997, the $175.00 child support for the Child Bobbie Michelle Truax to be paid by me her father Robert Lee Truax Jr. underwent an offset of $87.50--$87.50 being the balance owed me by the Mother Mary Michele (Meka Interiano Truax) Lindsey as restitution for a $289.00 bus ticket bought on December 22, 1996--an item for which Bobbie in behalf of Mary had given me $201.50 in total prior to November 1997; AND WHEREAS, I Robert Lee Truax Jr. the Father of the Child Bobbie Michelle Truax have in my possession a canceled check for the remaining $87.50 paid by me in November 1997 as child support for my daughter Bobbie Michelle Truax; AND WHEREAS, for the month of December 1997, the $175.00 child support for the Child Bobbie Michelle Trusx to be paid by me her father Robert 1 . 2 Lee Truax Jr. underwent an offset of $125.00--$125.00 being the amount determined to be the restitutional financial equivalent of the five (5) days visitation time the Hother Hary Nichele (Heka Interiano Truax) Lindsey did not let me have with Bobbie from November 26, 1997, through December I, 1997, according to the following: a. The total dollar amount of child support payments to be made by Robert from September 1, 1997, through August 31, 1998, was to have been twenty-one hundred dollars. b. The total number of days visitation time authorized Robert from September I, 1997, through August 31, 199B, is eighty-four (84)--the eighty- four (84) days being comprised of the five (5) days from November 26, 1997, through December 1, 1997, plus the twelve (12) days from December 23, 1997, through January 4, 199B, plus the sixty-seven (67) days from June II, 1998, through August 17, 1998. c. The total number of days visitation time Hary did not let Robert have with Bobbie from November 26, 1997, through December I, 1997, was five (5). d. Twenty-one hundred dollars divided by eighty-four times five is one hundred twenty-five dollars. AND WHEREAS, I Robert Lee Truax Jr. the Father of the Child Bobbie Hichelle Truax have in my possession a canceled check for the remaining $50.00 paid by me in December 1997 as child support for my daughter Bobbie Michelle Truax; AND WHEREAS, for the months of January 1998 and February 1998, the combined $350.00 child support for the Child Bobbie Michelle Truax to be paid by me her father Robert Lee Truax Jr. underwent an offset of $300.00--$300.00 being the amount determined to be the restitutional financial equivalent of the twelve (12) days visitation time the Mother Hary Michele (Heka Interiano Truax) Lindsey did not let me have with Bobbie from December 23, 1997, through January 4, 1998, according to the following: a. The total dollar amount of child support payments to be made by Robert from September I, 1997, through August 31, 1998, was to have been twenty-one hundred dollars. b. The total number of days visitation time authorized Robert from September 1, 1997, through August 31, 1998, is eighty-four (84)--the eighty- four (84) days being comprised of the five (5) days from November 26, 1997, through December I, 1997, plus the twelve (12) days from December 23, 1997, through January 4, 1998, plus the sixty-seven (67) days from June II, 1998, through August 17, 1998. c. The total number of days visitation time Hary did not let Robert have with Bobbie from December 23, 1997, through January 4, 1998, was twelve (12). d. Twenty-one hundred dollars divided by eighty-four times twelve is three hundred dollars. AND WHEREAS, the following statement was made on December 2, 1997: "Beginning on December 20, 1997, all future child support payments for the Child Bobbie Michelle Truax to be paid by her father Robert Lee Truax Jr. includin~child support payments which undergo offsets because the Hother Hary Michele ~eka Interiano Trua~ Lindsey fails to comply in letting the Child Bobbie Michelle Truax visit her father Robert Lee Truax Jr. . . . will be paid only if and when and after the Mother Mary Michele [Heka Interiano TruaEJ Lindsey delivers the Child Bobbie Michelle Truax into the care of her father Robert Lee Truax Jr."; I Robert Lee Truax Jr. the Father of the Child Bobbie Hichelle Truax will make a payment of the remaining combined $50.00 child support for my daughter Bobbie Hichelle Truax for the months of January 1998 and February 1998 as well as any payments of child support for my daughter Bobbie Michelle Truax for the months beyond February 1998 which come and go only if and when and after the Mother Mary Michele (~Ieka Interiano Truax) Lindsey delivers my daughter Bobbie Michelle Truax into my care. Mary Michele (Meka Interiano Truax) Lindsey the Mother of the Child . . . 3 Bobbie Michelle Truax is to deliver the Child Bobbie Michelle Truax into the care of her father Robert Lee Truax Jr. on Thursday June 11, 1998, at 4:00 PM Eastern Daylight Savings Time on the front stoop at 42 West Locust Street, Mechanicsburg, Pennsylvania 17055. IN WITNESS WHEREOF, I Robert Lee Truax Jr. set my signature below. JJ,J.~t~Jj ROBERT LEE TRUAX, Jj(. Sworn to and subscribed before copy and stamped envelope enclosed for: Mary Michele Lindsey 42 West Locust Street Mechanicsburg, PA 17055 I . MARY MICHELE LINDSEY, Plaintiff IN THE COURT OF CO~lMON PLEAS 01' CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 97-1401 CIVIL TERM CIVIL ACTION - LAW ROBERT LEE TRUAX, JR. Defendant IN CUSTODY OFFICIAL NOTIFICATION OF SPECIFIC DATE, TIME, AND PLACE FOR THE EXCHANGE OF CUSTODY AND NOW, this ) ) iJ... day of , 1998, upon consideration of my providing at least two (2) w notice to Mary Michele (Meka Interiano Truax) Lindsey the Mother of the Child Bobbie Michelle Truax that I Robert Lee Truax Jr. the Father of the Child Bobbie Michelle Truax intend to transport the Child Bobbie Michelle Truax by car relative to my receiving physical custody of the Child Bobbie Michelle Truax, I Robert Lee Trusx Jr. the Father of the Child Bobbie Michelle Truax do hereby submit the following: 1. I Robert Lee Truax Jr. the Father of the Child Bobbie Michelle Trusx will arrive by car on Thursday June II, 1998, by 4:00 PM EDST at 42 West Locust Street, Mechanicsburg, Pennsylvania 17055, to receive physical custody of my daughter Bobbie Michelle Trusx from her mother Mary Michele (Meka Interiano Truax) Lindsey and to begin transporting my daughter Bobbie Michelle Truax to the state of Tennessee. 2. I Robert Lee Truax Jr. the Father of the Child Bobbie Michelle Truax requested the Honorable Court of Common Pleas of Cumberland County, Pennsylvania, on May I, 1998, to have a law enforcement officer present on Thursday June 11, 1998, by 4:00 PM EDST at 42 West Locu~t Street, Mechanicsburg, Pennsylvania 17055, in order to facilitate the exchange of physical custody of my daughter Bobbie Michelle Truax from her mother Mary Michele (Meka Interisno Truax) Lindsey to me. 3. Be it known the specific date for the exchange of custody is Thursday June 11, 1998. 4. Be it known the specific time for the exchange of custody is 4:00 PM Eastern Daylight Savings Time. 5. Be it kno~~ the specific place for the exchange of custody is the front stoop at 42 West Locust Street, Mechanicsburg, Pennsylvania 17055. AND WHEREAS, for each and every month since February 1987 through and including October 1997, I Robert Lee Truax Jr. the Father of the Child Bobbie Michelle Truax have paid $175.00 child support for my daughter Bobbie Michelle Truax; AND WHEREAS, I Robert Lee Truax Jr. the Father of the Child Bobbie Michelle Truax have in my possession either canceled checks or other receipts for sll child support payments msde by me for my daughter Bobbie Michelle Truax from February 1987 through and including October 1997; AND WHEREAS, for the month of November 1997, the $175.00 child support for the Child Bobbie Michelle Truax to be paid by me her father Robert Lee Truax Jr. underwent an offset of $87.50--$87.50 being the balance owed me by the Mother Mary Michele (Meks Interiano Truax) Lindsey as restitution for a $289.00 bus ticket bought on December 22, 1996--an item for which Bobbie in behalf of Mary hsd given me $201.50 in total prior to November 1997; AND WHEREAS, I Robert Lee Truax Jr. the Father of the Child Bobbie Michelle Truax have in my possession a canceled check for the remaining $87.50 paid by me in November 1997 as child support for my daughter Bobbie Michelle Truax; AND WHEREAS, for the month of December 1997, the $175.00 child support for the Child Bobbie Michelle Truax to be paid by me her father Robert 1 2 Lee Truax Jr. underwent an offset of $125.00--$125.00 being the smount determined to be the reatitutional financial equivalent of the five (5) days visitation time the Mother Mary Michele (Meka Intcriano Truax) Lindscy did not lct mc have with Bobbie from Novcmber 26, 1997, through Deccmber 1, 1997, according to the following: a. Thc total dollar amount of child support paymcnts to be made by Robcrt from September 1, 1997, through August 31, 1998, was to havc becn twenty-one hundred dollars. b. The total number of daya visitation time authorized Robert from Septcmber I, 1997, through August 31, 1998, is eighty-four (84)--the cighty- four (84) daya being compriscd of thc five (5) days from Novembcr 26, 1997, through Dccember I, 1997, plus the twclve (12) days from Dccember 23, 1997, through January 4, 1998, plus the sixty-sevcn (67) days from June II, 1998, through August 17, 1998. c. The total number of days visitation time Mary did not let Robert have with Bobbie from November 26, 1997, through December I, 1997, was five (5). d. Twcnty-onc hundred dollars divided by eighty-four times five is one hundred twenty-five dollars. AND WHEREAS, I Robert Lee Truax Jr. the Father of the Child Bobbie Michelle Truax have in my possession a cancelcd check for the rcmaining $50.00 paid by me in December 1997 as child support for my daughter Bobbie Michelle Truax; AND WHEREAS, for the months of January 1998 and February 1998, the combined $350.00 child support for the Child Bobbie Michelle Truax to be paid by me her fathcr Robert Lee Trusx Jr. underwent an offset of $300.00--$300.00 being the amount detcrmined to be the restitutional financial cquivalent of the twelve (12) days visitation time the Mother Mary Michelc (Meka Interiano Trusx) Lindsey did not let me havc with Bobbie from December 23, 1997, through Janusry 4, 1998, according to the following: a. The total dollar amount of child support paymcnts to bc made by Robert from Septcmber I, 1997, through August 31, 1998, wss to hsve been twenty-one hundred dollars. b. Thc total numbcr of days visitation timc authorizcd Robcrt from Septcmbcr 1, 1997, through August 31, 1998, is eighty-four (84)--the eighty- four (84) days being compriscd of the fivc (5) days from Novembcr 26, 1997, through Deccmber I, 1997, plus the twelvc (12) days from Deccmbcr 23, 1997, through Jsnuary 4, 1998, plus the sixty-seven (67) days from June II, 1998, through August 17, 1998. ' C. 'rhl' tntnl n"mlll'r of dny" vl"ltntfnn tlm.. Hnry did not ll't Il"bert bnvl' with lIobble from J)ecelllbur 23, 1997, through ,)nnllary 4, 1998, was twelve (12). d. Twenty-one hundred dollars divided by cighty-four times twelvc is three hundred dollars. AND WHEREAS, the following statcment was made on Decembcr 2, 1997: "Beginning on Decembcr 20, 1997, all future child support payments for the Child Bobbie Michelle Truax to bc paid by her father Robert Lee Truax Jr. including child support payments which undergo offsets because the Mother Mary Michele (8eka Interiano Truajil Lindsey fails to comply in letting the Child Bobbie Michelle Trusx visit her father Robert Lee Truax Jr. . . . will be paid only if and when and after the Mother Msry Michele [fleka Interiano TruaEJ Lindsey delivers the Child Bobbie Michelle Truax into the care of her father Robert Lce Truax Jr."; I Robert Lec Truax Jr. the Father of the Child Bobbic Michelle Truax will make a psyment of the remaining combined $50.00 child support for my daughter Bobbie Michelle Truax for the months of January 1998 snd February 1998 as well as any psyments of child support for my daughter Bobbie Michelle Truax for the months beyond February 1998 which comc and go only if and when and after the Mother Mary Michele (Meka Interiano Truax) Lindsey delivers my daughter Bobbie Michelle Truax into my care. Mary Michele (Meka Interiano Truax) Lindsey the Mother of the Child . , &UN 29 1998 To Richard J. Pierce the Court Administrator at One Courthouse Square, Carlisle, Pennsylvania 17013; Mary Michele (Meka Interiano Truax) Lindsey the Mother of Bobbie Michelle Truax at 42 West Locust Street, Mechanicsburg, Pennsylvania 17055; and Whomever Else It May Concern: Regarding the Child Bobbie Michelle Truax who was born in Shelby County, Tenneseee, on July lB, 19B4, and her parents Mary Michele Lindsey and Robert Lee Truax Jr. in Case Number 97-1401 Civil Term in the Court of Common Pleas of Cumberland County, Pennsylvania, the following is a follow-up to my document dated June 17, 199B: Whereas the Mother Mary Michele Lindsey moved the Child Bobbie Michelle Truax from Memphis, Shelby County, Tennessee, to Mechanicsburg, Cumberland County, Pennsylvania, on or before July 15, 1995, without notifying the Fsther Robert Lee Truax Jr. beforehand; and Wheress the Mother Mary Michele Lindsey moved the Child Bobbie Michelle Truax from Memphis, Shelby County, Tennessee, to Mechanicsburg, Cumberland County, Pennsylvania, on or before July IS, 1995, apparently with no consideration for the Father Robert Lee Truax Jr.'s visitation rights; and Whereas the Mother Mary Michele Lindsey moved the Child Bobbie Michelle Truax from Memphis, Shelby County, Tennessee, to Mechanicsburg, Cumberland County, Pennsylvania, on or before July 15, 1995, apparently with no willingness to encourage a continuing relationship between the Child Bobbie Michelle Truax and her father Robert Lee Truax Jr.; and Whereas the Mother Mary Michele Lindsey disregarded a 1987 Tennessee court order and did not let the Father Robert Lee Truax Jr. visit the Child Bobbie Michelle Truax at any time on July 18, 1995; and Whereas the Mother Mary Michele Lindsey disregarded a 1987 Tennessee court order and did not let the Father Robert Lee Truax Jr. visit the Child Bobbie Michelle Truax at any time during the weekend of July 21, 1995, through July 23, 1995; and Whereas the Mother Mary Michele Lindsey and the Father Robert Lee Truax Jr. signed an Amendment Agreement in May 1996 stating that the Mother Mary Michele Lindsey would deliver the Child Bobbie Michelle Truax to her father Robert Lee Truax Jr. inside the Harrisburg Greyhound Bus Station on December 23, 1996, for a visitation time beginning on December 23, 1996, and continuing through January 2, 1997; and Whereas the Mother Mary Michele Lindsey disregarded the Amendment Agreement signed in May 1996 and did not deliver the Child Bobbie Michelle Truax to her father Robert Lee Truax Jr. on December 23, 1996; and Whereas the Mother Mary Michele Lindsey disregarded the Amendment Agreement signed in Msy 1996 and did not let the Father Robert Lee Truax Jr. visit the Child Bobbie Michelle Trusx at any time during the months of December 1996 and January 1997; and Whereas an order of the Court of Common Pleas of Cumberland County, Pennsylvania, dated April 2B, 1997, provides for Robert Lee Truax Jr. the Father of the Child Bobbie Michelle Truax to have hsd visitation time with his dsughter Bobbie Michelle Trusx from December 23, 1996, through January 2, 1997, and from November 26, 1997, through December I, 1997, and from December 23, 1997, through January 4, 1998, and from June 11, 199B, through August 17, 1998; and Whereas Mary Michele (Meka Interiano Truax) Lindsey has flagrantly and repeatedly disregarded the order of the Court of Common Pleas of Cumberland County, Pennsylvania, dated April 28, 1997, by not letting Robert Lee Truax Jr. the Father of the Child Bobbie Michelle Truax have any visitation time at all with his daughter Bobbie Michelle Truax since September I, 1997; and Whereas it was stated on December 2, 1997, that "Beginning on December 20, 1997, all future child support payments for the Child Bobbie Michelle Truax to be paid by her father Robert Lee Truax Jr. including child support payments which undergo offsets because the Mother Mary Michele Lindsey fails to comply in letting the Child Bobbie Michelle Truax visit her father Robert Lee Truax Jr. . . . will be paid only if and when snd after the Mother 1 2 Mary Michele Lindsey delivers the Child Bobbie Michelle Truax into the care of her father Robert Lee Truax Jr. for the purpose of exchange of custody and visitation . . ." and that "Failure by Mary to facilitate Bobbie visiting Robert will result in a cessation of child support payments"; and Whereas it was stated on January 5, 1998, that "For the months of January 1998 and February 1998, the combined $350.00 child support for the Child Bobbie Michelle Truax to be paid by her father Robert Lee Truax Jr. will undergo an offset of $300.00--$300.00 being the amount determined to be the restitutional financial equivalent of the twelve (12) days visitation time the Mother Mary Michele Lindsey did not let the Father Robert Lee Truax Jr. have from December 23, 1997, through January 4, 1998, according to the following: The total dollar amount of child support payments to be made by Robert from September 1, 1997, through August 31, 1998, was to have been twenty-one hundred dollars. The total number of days visitation time authorized Robert . . . from September 1, 1997, through August 31, 1998, is eighty-four (84)- the eighty-four (84) days being comprised of the five (5) days from November 26, 1997, through December 1, 1997, plus the twelve (12) days from December 23, 1997, through January 4, 1998, plus the sixty-seven (67) days from June 11, 1998, through August 17, 1998. The total number of days visitation time Mary did not let Robert have from December 23, 1997, through January 4, 1998, was twelve (12). Twenty-one hundred dollars divided by eighty-four times twelve is three hundred dollars" and "A payment of the remaining combined $50.00 child support for the months of January 1998 and February 1998 will be paid only if and when and after the Mother Mary Michele Lindsey delivers the Child Bobbie Michelle Truax into the care of her father Robert Lee Truax Jr. for the purpose of exchange of custody and visitation . . ." and that "Another failure by Mary to facilitate Bobbie visiting Robert will result in a forfeiture of child support payments" and "Savings bonds equivalent in value to child support payments for the Child Bobbie Michelle Truax which are forfeited by her mother Mary Michele Lindsey and not paid by her father Robert Lee Truax Jr. . . . will be purchased by him and set aside for him to give Bobbie after July 18, 2002 (her eighteenth birthday)"; and Wheress it was stated on February 5, 1998, that "A payment of the remaining combined $50.00 child support for the months of January 1998 snd February 1998 as well as any payments of child support for the months beyond February 1998 will be paid only if and when and after the Mother Mary Michele Lindsey delivers the Child Bobbie Michelle Truax into the care of her father Robert Lee Truax Jr. for the purpose of exchange of custody and visitation . . ."; and Whereas the Father Robert Lee Truax Jr. notified the Mother Mary Michele (Meka Interiano Truax) Lindsey on April 7, 1998, that he would arrive by car st 42 West Locust Street, Mechanicsburg, Pennsylvania 17055, by 4:00 PM EDST on Thursday June 11, 1998, to receive physical custody of his daughter Bobbie Michelle Truax; and Whereas it was stated on April 7, 1998, that "Failure by the Mother Mary Michele Lindsey to facilitate the Father Robert Lee Truax Jr. receiving physical custody of the Child Bobbie Michelle Truax at 4:00 PM EDST on Thursday June 11, 1998, will result in a forfeiture of child support psyments" and "Ssvings bonds equivalent in value to child support payments for the Child Bobbie Michelle Truax (minus offsets of child support payments which undergo offsets) which are forfeited by her mother Msry Michele Lindsey and not paid by her father Robert Lee Truax Jr. . . . will be purchsscd by him and set aside for him to give Bobbie after July i8, 2002 ,her eighteenth birthday)"; and Whereas the Father Robert Lee Truax Jr. notified the Mother Mary Michele (Meka lnteriano Truax) Lindsey on May 11, 1998, that he hsd requested the Court of Common Pleas of Cumberland County, Pennsylvania, on May 1, 1998, to have a law enforcement officer present on Thursday June 11, 1998, by 4:00 PM EDST at 42 West Locust Street, Mechanicsburg, Pennsylvania 17055, in order to facilitate the exchange of physical custddy of the Child Bobbie Michelle Truax from her the Mother to him the Father; and Whereas the Father Robert Lee Trusx Jr. reminded the Mother Msry Michele Lindsey on May 11, 1998, thst he the Father would arrive by car on Thursday June 11, 1998, by 4:00 PM EDST at 42 West Locust Street, Mechanicsburg, Pennsylvania 17055, to receive physical custody of his daughter Bobbie Michelle Truax, and that she the Mother was to deliver the Child Bobbie 3 Michelle Truax into his core on Thursday June II, 1998, at 4:00 PM Eastern Daylight Savings Time on the front stoop at 42 West Locust Street, Mechanicsburg, Pennsylvania 17055; and Whereas for each and every month since February 1987 through and including October 1997, the Father Robert Lee Truax Jr. has paid $175.00 child support for his daughter Bobbie Michelle Trusx, for which he has in his possession either canceled checks or other receipts for all child support payments made by him for his daughter Bobbie Michelle Truax from February 1987 through and including October 1997; and Whereas for the month of November 1997, the $175.00 child support for the Child Bobbie Michelle Truax to be paid by her father Robert Lee Truax Jr. underwent an offset of $87.50 ($87.50 being the bslance owed the Father Robert Lee Trusx Jr. by the Mother Msry Michele (Meka Interiano Truax) Lindsey as restitution for a $289.00 bus t1cket bought on December 22, 1996--an item for which Bobbie in behalf of Mary had given Robert $201.50 in total prior to November 1997), for which he has in his possession a canceled check for the remaining $87.50 paid by him in November 1997 as child support for his daughter Bobbie Michelle Truax; and Whereas for the month of December 1997, the $175.00 child support for the Child Bobbie Michelle Truax to be paid by her father Robert Lee Truax Jr. underwent an offset of $125.00 ($125.00 being the amount determined to be the restitutional financial equivalent of the five (5) days visitation time the Mother Mary Michele (Meka Interiano Truax) Lindsey did not let the Father Robert Lee Truax Jr. have with his daughter Bobbie Michelle Truax from November 26, 1997, through December I, 1997), for which he has in his possession a canceled check for the remaining $50.00 paid by him in December 1997 as child support for his daughter Bobbie Michelle Truax; and Whereas for the months of Jsnuary 1998 and February 1998, the combined $350.00 child support for the Child Bobbie Michelle Truax to be paid by her father Robert Lee Truax Jr. underwent an offset of $300.00 ($300.00 being the amount determined to be the restitutional financial equivalent of the twelve (12) dsys visitation time the Mother Mary Michele (Meka Interiano Truax) Lindsey did not let the Father Robert Lee Truax Jr. have with his daughter Bobbie Michelle Truax from December 23, 1997, through January 4, 1998), for which he was to make a payment of the remaining combined $50.00 child support for his daughter Bobbie Michelle Truax for the months of January 1998 and February 1998 as well as any payments of child support for his daughter Bobbie Michelle Truax for the months beyond February 1998 which come and go only if and when and after the Mother Mary Michele Lindsey delivered his dsughter Bobbie Michelle Truax into his carej and Whereas the Father Robert Lee Truax Jr. (along with his parents) was at 42 West Locust Street, Mechanicsburg, Pennsylvania 17055, on Thursday June II, 1998, from 3:45 PM EDST until 4:15 PM EDST, in order both to receive physical custody of his daughter Bobbie Michelle Truax and to make payment of child support for his daughter Bobbie Michelle Truax through June 1998; and Whereas the Mother Mary Michele (Meka Interiano Truax) Lindsey disregarded the order of the Court of Common Pleas of Cumberland County, Pennsylvanis, dated April 28, 1997, and did not allow the Father Robert Lee Truax Jr. to pick up the Child Bobbie Michelle Truax on Thursday June II, 1998, as ordered by the Court of Common Pleas of Cumberland County, Pennsylvania, on April 28, 1997. as une 01 its provisfons for the Father Robert Lee Truax Jr.'s visitation rightsj and Whereas the Court of Common Pleas of Cumberland County, Pennsylvania, did not have a law enforcement officer present at 42 West Locust Street, Mechanicsburg, Pennsylvania 17055, at 4:00 PM EDST on Thursday June II, 1998, even though the Father Robert Lee Truax Jr. had requested the Court of Common Pleas of Cumberland County, Pennsylvania, on May I, 1998, to have a law enforcement officer present at 42 West LocuSt Street, Mechanicsburg, Pennsylvania 17055, by 4:00 PM EDST on Thursday June II, 1998, in order to facilitate the exchange of physical custody of the Child Bobbie Michelle Truax from the Mother Mary Michele Lindsey to the Father Robert Lee Truax Jr. at 4:00 PM EDST on Thursday June II, 1998; and Wheress the Father Robert Lee Truax Jr. (along with his parents) stayed overnight on Thursdsy June II, 1998, at a motel in Mechsnicsburg, 4 Pennsylvania, in order to return to 42 West Locust Street, Mechanicsburg, Pennsylvania 17055, on Friday June 12, 1998, in the hope of picking up the Child Bobbie Michelle Truax on Friday June 12, 1998; and Whereas the Father Robert Lee Truax Jr. (along with his parents) returned to 42 West Locust Street, Mechanicsburg, Pennsylvania 17055, on Fridsy June 12, 1998, in the hope of picking up the Child Bobbie Michelle Trusx on Fridsy June 12, 1998; and Whereas the Mother Mary Michele (Meka Interiano Truax) Lindsey did not allow the Father Robert Lee Truax Jr. to pick up the Child Bobbie Michelle Truax on Friday June 12, 1998; and Whereas the Mother Mary Michele (Beka Interiano Truax) Lindsey has not even let the Father Robert Lee Truax Jr. see the Child Bobbie Michelle Truax since September I, 1991; and Whereas the Mother Mary Michele (Meka Interiano Truax) Lindsey has failed to facilitate the Child Bobbie Michelle Truax visiting her father Robert Lee Truax Jr. from June 11, 1998, through August 17, 1998--a period of time ordered by the Court of Common Pleas of Cumberland County, Pennsylvania, on April 28, 1997, to be visitation time for the Father Robert Lee Trusx Jr. with his daughter Bobbie Michelle Truax; snd Whereas the Mother Mary Michele Lindsey's failure on June 11, 1998, to facilitate the Child Bobbie Michelle Trusx visiting her father Robert Lee Truax Jr. results in a forfeiture of child support payments; and Wheress savings bonds equivalent in value to child support payments for the Child Bobbie Michelle Truax (minus offsets of child support payments which undergo offsets) which are forfeited by the Mother Mary Michele Lindsey and not paid by the Fsther Robert Lee Truax Jr. are to be purchased by the Father Robert Lee Truax Jr. and set aside for him to give his dsughter Bobbie Michele Truax after July 18, 2002 (her eighteenth birthdsy); I Robert Lee Truax Jr. the Father of the Child Bobbie Michelle Truax do hereby bring up-to-date the financial aspect of child support for my daughter Bobbie Michelle Truax relative to child support payments to be paid by me which undergo offsets because Mary M~chele (Meka Interiano Truax) Lindsey the Mother of the Child Bobbie Michelle Truax has not allowed me any visitation time at all with my daughter Bobbie Michelle Truax since September 1, 1997, and most recently did not allow me to pick up my daughter Bobbie Michelle Truax on June 11, 1998, as provided by and in accordance with the Orders of Court in the Court of Common Pleas of Cumberland County, Pennsylvania, dated April 28, 1997, and February 23, 1998, and May 27, 1998. The following is how it is: a. The remaining combined $50.00 child support for the months of January 1998 and February 1998 plus $175.00 child support for the month of March 1998 plus $175.00 child support for the month of April 1998 plus $175.00 child support for the month of May 1998 plus $175.00 child support for the month of June 1998 equals $750.00. b. Transportation costs for the purchase of gasoline in traveling from Cordova, Tennessee, to Mechsnicsburg, Pennsylvania, and back from June 10, 1998, through June 13, 1998, were $97.00. c. The restitutional financial equivalent of the nineteen (19) days visitation time the Mother Mary Michele (Meka Interiano Truax) Lindsey will not have let me have with my daughter Bobbie Michelle Truax from June II, 1998, through June 30, 1998, is $475.00, according to the following: 1. The total dollar amount of child support psyments to be made by me from September I, 1997, through August 31, 1998, was to have been twenty-one hundred dollars. 2. The total number of days visitation time authorized me from September I, 1997, through August 31, 1998, is eighty-four (84)--the eighty-four (84) days being comprised of the five (5) dsys from November 26, 1997, through December I, 1997, plus the twelve (12) days from December 23, 1997, through January 4, 1998, plus the nineteen (19) days from June 11, 1998, through June 30, 1998, plus the forty-eight (48) days from June 30, 1998, 5 through August 17, 1998. 3. The total number of days visitation time Mary will not have let me have with Bobbie from June 11, 1998, through June 30, 1998, is nineteen (19). 4. Twenty-one hundred dollars divided by eighty-four times nineteen is four hundred seventy-five dollars. d. plus $475.00 as visitation time $97.00 in transportation costs for the purchase of gasoline the restitutionsl financial equivalent of nineteen (19) days equals $572.00 in offsets of child support payments. e. $750.00 minus $572.00 equals $178.00 to be used by me in purchasing savings bonds to be set aside for me to give Bobbie after July 18, 2002 (her eighteenth birthday). However, since savings bonds can be purchased only in increments of $25.00, I only used $175.00 to purchase savings bonds in accordance with the sentence immediately preceding this sentence and I set aside a check for the remaining $3.00 to give Bobbie the next time she is with me. f. Beginning in July 1998 I will use the $175.00 each month thst Mary has forfeited in child support payments to purchase ssvings bonds to be set aside for me to give Bobbie after July 18, 2002 (her eighteenth birthday). The action by me stated in accordance with the sentence immediately precding this sentence will continue until one of the fOllowing occurs: 1. I die. 2. Bobbie dies. 3. Mary facilitates Bobbie visiting me for forty-eight (48) days--forty-eight (48) days being the number of days visitation time authorized me from June 30, 1998, through August 17, 1998--and the forty- eighth day of my actual visitation time with Bobbie as facilitated by Mary in accordance with the first part of this sentence hss ended. g. In the event Mary facilitates Bobbie visiting me for forty- eight (48) days and the forty-eighth day of my actual visitation time with Bobbie as facilitated by Mary in accordance with the first part of this sentence has ended, I will discontinue using $175.00 each month to purchsse savings bonds to be set aside for me to give Bobbie after July 18, 2002 (her eighteenth birthday). Additionally whereas (1) the Mother Mary Michele (Meka Interiano Trusx) Lindsey did not deliver the Child Bobbie Michelle Truax to her father Robert Lee Truax Jr. at the Harrisburg Greyhound Bus Station on December 23, 1996, and (2) the Mother Mary Michele (Meka Interisno Truax) Lindsey did not send the Child Bobbie Michelle Truax on an airplane from Harrisburg, Pennsylvania, to Memphis, Tennessee, to visit her father Robert Lee Truax Jr. on November 26, 1997, and (3) the Mother Mary Michele (Meka Interiano Truax) Lindsey did not send the Child Bobbie Michelle Truax on an airplane from Harrisburg, Pennsylvsnia, to Memphis, Tennessee, to visit her father Robert Lee Truax Jr. on December 23, 1997, and (4) the Mother Mary Michele (Meka Interiano Truax) Lindsey did not allow the Father Robert Lee Truax Jr. to pick up the Child Bobbie Michelle Truax at 42 West Locust Street, Mechanicsburg, Pennsylvania 17055, on June 11, 1998, as provided by sod in accordance with the Orders of Court in the Court of Common Pleas of Cumberland County, Pennsylvania, dated April 28, 1997, and February 23, 1998, and May 27, 1998; Beginning on June 30, 1998, the responsibility and expense of providing transportation for the Child Bobbie Michelle Truax to visit her father Robert Lee Truax Jr. rests solely with the Mother Mary Michele (Meka Interiano Truax) Lindsey, and the responsibility and expense of providing transportation for the Child Bobbie Michelle Truax to return to her mother Mary Michele Lindsey rests solely with the Fsther Robert Lee Truax Jr. Therefore for instance, if the Child Bobbie Michelle Truax is to fly to visit her father Robert Lee Truax Jr. it is the responsibility of the Mother Mary Michele (Meka Interiano Truax) Lindsey to purchase and pay for a one-way ticket to get the Child from the Mother to the Father, and it is the responsibility of the Father Robert Lee Truax Jr. to purchsse and pay for a . . 6 one-way ticket to get the Child from the Father back to the Mother. I Robert Lee Truax Jr. the Father of the Child Bobbie Michelle Truax do hereby confirm formally that I am open to the Mother Mary mchele (Meka Interiano Truax) Lindsey getting my daughter Bobbie Michelle Truax to me for a visit at any time during the course of a year. All Mary need do is purchase and pay for a one-way ticket to get Bobbie to me, and I in turn will purchase and pay for a one-way ticket to get Bobbie back to Mary. Mary may send Bobbie to me by bus, plane, or train, and I will send Bobbie back to Mary by the same mode of transportation as Bobbie comea to me. If Mary gets Bobbie to me by car, I will get Bobbie back to Mary by car. IN TESTIMONY AND WT.TNESS WHEROF, I Robert Lee Truax Jr. aet my signature below. RO~ ~AX~I ~ 2~ 19~; DATE(/ I ~ me this t dny 0 Sworn to and subscribed before I H98. MY COMMISSION EXPIRES: ,~ , -... -- -.......... fi';rI";f'l""Q i.ljS~"".-"'''''''.'' 'V . , .... To Whoever Is the Court Administrator for the Court of Common Pleas of Cumberland County, Pennsylvania, at One Courthouse Square, Carlisle, Pennsylvania 17013; Mary Michele Meka (also known as Mary Michele Interiano, Mary Michele Truax, and Mary Michele Lindsey) the Mother of the Child Bobbie Michelle Truax at 42 West Locust Street, Mechanicsburg, Pennsylvania 17055; and Whomever Else It May Concern: Regarding the Child Bobbie Michelle Truax who was born in Shelby County, Tennessee, on July 18, 1984, and her parents Mary Michele Meka (also known as Mary Michele Interiano, Mary Michele Truax, snd Mary Michele Lindsey) and Robert Lee Trusx Jr. in Case Number 97-1401 Civil Term in the Court of Common Pleas,of Cumberland County, Pennsylvania: Whereas Msry Michele Meka (also known as Mary Michele Interiano, Mary Michele Trusx, and Mary Michele Lindsey) the Mother of the Child Bobbie M~chelle Truax moved the Child Bobbie Michelle Truax from Memphis, Shelby County, Tennessee, to Mechanicsburg, Cumberland County, Pennsylvania, on or before July 15, 1995, without notifying me Robert Lee Truax Jr. the Father of the Child Bobbie Michelle Truax beforehand; and Whereas Mary Michele Meka (also known as Mary Michele Interiano, Mary Michele Truax, and Mary ~Iichele Lindsey) the Mother of the Child Bobbie Michelle Trusx moved the Child Bobbie Michelle Truax from Memphis, Shelby County, Tennessee, to Mechanicsburg, Cumberland County, Pennsylvania, on or before July 15, 1995, apparently with no consideration for the visitation rights ascribed to me Robert Lee Truax Jr. the Father of the Child Bobbie Michelle Truax by a 1987 Tennessee court order; and Whereas Mary Michele Meka (also known as Mary Michele Interiano, Mary Michele Truax, and Mary Michele Lindsey) the Mother of the Child Bobbie Michelle Truax moved the Child Bobbie Michelle Truax from Memphis, Shelby County, Tennessee, to Mechsnicsburg, Cumberland County, Pennsylvsnia, on or before July 15, 1995, apparently with no willingness to encourage a continuing relationship between the Child Bobbie Michelle Truax and me Robert Lee Truax Jr. the Father of the Child Bobbie Michelle Truax; and Whereas an order of the Court of Common Pleas of Cumberland County, Pennsylvania, dated April 28, 1997, provides for me Robert Lee Trusx Jr. the Father of the Child Bobbie Michelle Truax to have had visitation time with my daughter Bobbie Michelle Truax from November 26, 1997, through December 1, 1997, and from December 23, 1997, through January 4, 1998, and from June 11, 1998, through August 17, 1998; and Whereas Msry Michele Meka (also known as Mary Michele Interiano, Mary Michele Truax, and Mary Michele Lindsey) the Mother of the Child Bobbie Michelle Truax has flagrantly and repeatedly disregarded the order of the Court of Common Pleas of Cumberland County, Pennsylvania, dated April 28, 1997, by not letting me Robert Lee Truax Jr. the Father of the Child Bobbie Michelle Truax have any visitstion time at all with my daughter Bobbie Michelle Truax since September I, 1997, even though the order of the Court of Common Pleas of Cumberland County, Pennsylvania, dsted April 28, 1997, authorizes me Robert Lee Truax Jr. the Father of the Child Bobbie Michelle Truax to have had eighty-four (84) days.visitation time with my daughter Bobbie Michelle Truax during the one year period beginning on September 1, 1997, and continuing through August 31, 1998, and even though for each and every month since February 1987 through and including August 1998 I Robert Lee Truax Jr. the Father of the Child Bobbie Michelle Trusx can account for the child support payments made by me Robert Lee Trusx Jr. the Father of the Child Bobbie Michelle Truax for my daughter Bobbie Michelle Truax at the rate of $175.00 a month; and Whereas the Court of Common Pleas of Cumberland County, Pennsylvania, did not have a Isw enforcement officer present at 42 West Locust Street, Mechanicsburg, Pennsylvania 17055, at 4:00 PM EDST on Thursday June 11, 1998, to facilitate the exchange of physical custody of the Child Bobbie Michelle Truax from the Mother Mary Michele (Meka Interiano Truax) Lindsey to me the, Father Robert Lee Truax Jr., even though I the Father Robert Lee Trusx Jr. had requested the Court of Common Pleas of Cumberland County, Pennsylvania, on May 1, 1998, to hsve a law enforcement officer present at 42 West Locust Street, Mechanicsburg, Pennsylvania 17055, by 4:00 PM EDST on Thursday June 11, 1998, in order to facilitate the exchange of physical custody of the Child Bobbie Michelle Truax from the Mother Mary Michele (Meka Interiano Truax) 1 -.. 2 Lindsey to me the Father Robert Lee Truax Jr. at 4:00 PM EDST on Thursday June 11, 199B; I Robert Lee Truax Jr. the Father of the Child Bobbie Michelle Truax do hereby revert back to the Amendment Agreement signed by myself Robert Lee Trusx Jr. the Father of the Child Bobbie Michelle Truax and Mary Michele (Meka Interiano Truax) Lindsey the Mother of the Child Bobbie Michelle Truax in May 1996 granting me the Father Robert Lee Truax Jr. the following ninety-four (94) days visitation time for the one year period beginning on September 1, 1997, and continuing through August 31, 199B: Ten (10) days from 10:00 AM on December 23, 1997, until 10:00 AM on January 2, 199B; and Eighty-four (B4) days from 4:00 PM on June 5, 199B (the first Friday in June) until 6:00 PM on August 28, 199B (the fourth Friday in August). The forfeiture of child support payments brought about by Mary Michele (Meka Interiano Trusx) Lindsey's failure to facilitate my dsughter Bobbie Michelle Trusx visiting me her fsther Robert Lee Truax Jr. on June 11, 199B, will continue until I Robert Lee Truax Jr. the Father of the Child Bobbie Michelle Truax have received ninety-four (94) days visitation time with my daughter Bobbie Michelle Truax. In the event I Robert Lee Truax Jr. the Father of the Child Bobbie Michelle Truax receive ninety-four (94) days visitation time with my daughter Bobbie Michelle Truax beginning sometime on or after September 1, 1998, I Rebert Lee Truax Jr. the Father of the Child Bobbie Michelle Truax will make psyment as child support for my daughter Bobbie Michelle Truax the following funds which were utilized as offsets for visitstion time I Robert Lee Truax Jr. the Father of the Child Bobbie Michelle Truax did not receive but which I Robert Lee Truax Jr. the Father of the Child Bobbie Michelle Truax should have received as part of my visitation rights provided for and in accordance with the Order of Court in the Court of Common Pleas of Cumberland County, Pennsylvania, dsted April 2B, 1997, that Msry Michele (Meka Interiano Truax) Lindsey the Mother of the Child Bobbie Michelle Truax did not allow me Robert Lee Truax Jr. the Father of the Child Bobbie Michelle Truax to receive: $125.00 for the five (5) days from November 26, 1997, through December 1, 1997; and $300.00 for the twelve (12) days from December 23, 1997, through January 4, 199B; and $475.00 for the nineteen (19) days from June 11, 1998, through June 30, 199B. IN TESTIMONY AND WITNESS WHEREOF, I Robert Lee Truax Jr. the Father of the Child Bobbie Michelle Truax set my signature below. ~&.~~ ROBERT LEE TRUAX JItl Sworn to snd subscribed , ._:~ MY COMMISSION EXPIRES: ~ r.ommlSSlon Exptles 2.23-2000 } .. --. To Whoever Is the Court Administrator for the Court of Common Pless of Cumberland County, Pennsylvania, at One Courthouse Square, Carlisle, Pennsylvania 17013; Mary Michele Meka (also known as Mary Michele Interiano, Mary Michele Truax, and Msry Michele Lindsey) the Mother of the Child Bobbie Michelle Truax at 42 West Locust Street, Mechanicsburg, Pennsylvania 17055; and Whomever Else It May Concern: Regarding the Child Bobbie Michelle Trusx who waa born in Shelby County, Tennessee, on July 18, 1984, and her parents Mary Michele Meka (also known as Mary Michele Interiano, Mary Michele Truax, and Mary Michele Lindsey) and Robert Lee Truax Jr. in Case Number 97-1401 Civil Term in the Court of Common Pleas of Cumberland County, Pennsylvania: Wheress Mary Michele Meka (also known as Mary Michele Interiano, Mary Michele Truax, and Mary Michele Lindsey) the Mother of the Child Bobbie MIchelle LtUaX mov~d the Child Bobbie Michelle Truax from Memphis, Shelby County, Tennessee, to Mechanicsburg, Cumberland County, Pennsylvania, on or before July 15, 1995, without notifying me Robert Lee Trusx Jr. the Father of the Child Bobbie Michelle Trusx beforehand, and apparently with no consideration for the visitation rights ascribed to me Robert Lee Truax Jr. the Father of the Child Bobbie Michelle Truax by a 1987 Tennessee court order, and apparently with no willingness to encoursge a continuing relationship between the Child Bobbie Michelle Truax and me Robert Lee Truax Jr. the Father of the Child Bobbie Michelle Truax; and Whereas an order of the Court of Common Pleas of Cumberland County, Pennsylvania, dated April 28, 1997, provides for me Robert Lee Truax Jr. the Father of the Child Bobbie Michelle Truax to have had visitation time with my daughter Bobbie Michelle Truax from November 26, 1997, through December 1, 1997, and fcom December 23, 1997, through January 4, 1998, and from June 11, 1998, through August 17, 1998; and Whereas Mary Michele Meka (also known as Mary Michele Interiano, Msry Michele Truax, and Mary Michele Lindsey) the Mother of the Child Bobbie Michelle Truax has flagrantly and repeatedly disregarded the order of the Court of Common Pleas of Cumberlsnd County, Pennsylvsnta, dated April 28, 1997, by not letting me Robert Lee Truax Jr. the Father of the Child Bobbie Michelle Truax have any visitation time at all with my daughter Bobbie Michelle Truax since September I, 1997, even though for each and every month since February 1987 I Robert Lee Truax Jr. the Father of the Child Bobbie Michelle Truax can account for the child support payments made by me Robert Lee Truax Jr. the Father of the Child Bobbie Michelle Truax for my daughter' Bobbie Michelle Truax at the rate of $175.00 a month; and Whereas the Court of Common Pleas of Cumberland County, Pennsylvania, did not have a law enforcement officer present at 42 West Locust Street, Mechanicsburg, Pennsylvania 17055, at 4:00 PM EDST on Thursday June II, 1998, to facilitate the exchsnge of physical custody of the Child Bobbie Michelle Truax from the Mother Mary Michele (Meka Interiano Truax) Lindsey to me the Father Robert Lee Truax Jr., even though I the Father Robert Lee Truax Jr. had requested the Court of Common Pleas of Cumberland County, Pennsylvania, on May I, 1998, to have a law enforcement officer present at 42 West Locust Street, Mechanicsburg, Pennsylvania 17055, by 4:00 PM EDST on Thursday June 11, 1998, in order to facilitate the exchange of physical custody of the Child Bobbie Michelle Truax from the Mother Mary Michele (Meka Interiano Truax) Lindsey to me the Father Robert L~e Truax Jr. at 4:00 PM EDST on Thursday June 11, 1998; I Robert Lee Truax Jr. the Father of the Child Bobbie Michelle Truax reverted back to the Amendment Agreement signed by myself Robert Lee Truax Jr. the Father of the Child Bobbie Michelle Truax and Mary Michele (Meka Interiano Truax) Lindsey the Mother of the Child Bobbie Michelle Truax in May 1996 granting me the Father Robert Lee Truax Jr. the following ninety-four (94) days visitation time for the one year period beginning on September I, 1997, and continuing through August 31, 1998: Ten (10) days fro~ 10:00 AM on December 23. 1997, until 10:00 AM on January 2, 1998; and Eighty-four (84) days from 4:00 PM on June 5, 1998 (the first Friday in June) until 6:00 PM on August 28, 1998 (the fourth Friday in August). The forfeiture of child support payments brought about by Mary Michele 1 " - 2 (Meka Interiano Truax) Lindsey's failure to facilitate my daughter Bobbie Michelle Truax visiting me her father Robert Lee Truax Jr. on June 11, 1998, will continue until I Robert Lee Truax Jr. the Father of the Child Bobbie Michelle Truax have received ninety-four (94) days visitation time with my daughter Bobbie Michelle Truax. In the event I Robert Lee Truax Jr. the Father of the Child Bobbie Michelle Truax receive ninety-four (94) days visitation time with my daughter Bobbie Michelle Truax, I Robert Lee Trusx Jr. the Father of the Child Bobbie Michelle Truax will make payment as child support for my dsughter Bobbie Michelle Truax the following funds which were utilized as offsets for visitation time I Robert Lee Truax Jr. the Father of the Child Bobbie Michelle Truax did not receive but which I Robert Lee Truax Jr. the Father of the Child Bobbie Michelle Truax should have received as part of my visitation rights provided for and in accordance with the Order of Court in the Court of Common Pleas of Cumberland County, ~ennsylvania, dated April 28, 1997, that Mary Michele (Meka Interiano Truax) Lindsey the Mother of the Child Bobbie Michelle Truax did not allow me Robert Lee Truax Jr. the Father of the Child Bobbie Michelle Truax to receive: $125.00 for the five (5) days from November 26, 1997, through December I, 1997; snd $300.00 for the twelve (12) days from December 23, 1997, through January 4, 1998; and $475.00 for the nineteen (19) dsys from June 11, 1998, through June 30, 1998. Additionally whereas Mary Michele (Meka Interiano Truax) Lindsey the Mother of the Child Bobbie Michelle Truax did not allow me Robert Lee Trusx Jr. the Father of the Child Bobbie Michelle Truax to pick up my daughter Bobbie Michelle Truax at 42 West Locust Street, Mechanicsburg, Pennsylvania 17055, on June 11, 1998; The responsibility and expense of providing transportation for the Child Bobbie Michelle Truax to visit me her father Robert Lee Truax Jr. rests solely with the Mother Msry Michele Meka (also known as Mary Michele Interiano, Mary Michele Truax, and Mary Michele Lindsey), and the responsibility and expense of providing transportation for the Child Bobbie Michelle Trusx to return to her mother Mary Michele Meka (also known as Mary Michele Interiano, Mary Michele Truax, and Mary Michele Lindsey) rests solely with me the Father Robert Lee Trusx Jr. This is notification to Mary Michele Meka (also known as Mary Michele Interiano, Mary Michele Truax, and Mary Michele Lindsey) the Mother of the Child Bobbie Michelle Truax that she Mary Michele Meka (slso known ss Mary Michele Interiano, Mary Michele Truax, and Mary Michele Lindsey) the Mother of the Child Bobbie Michelle Truax is to send the Child Bobbie Michelle Truax on Wednesday November 25, 1998, and again on Wednesdsy December 23, 1998, to visit me Robert Lee Truax Jr. the Father of the Child Bobbie Michelle Truax. This is a reminder to Mary that it is her responsibility to determine by what mode of transportation Bobbie is to travel, and to purchase and to pay for a one-way ticket to get Bobbie to me on Wednesday November 25, 1998, and again on Wednesday December 23, 1998; it is my responsibility to purchase and to psy for a one-way ticket to get Bobbie bsck to Mary on Monday November 30, 1998, and again on Sundsy Janusry 3, 1999. IN TESTIMONY AND WITNESS WHEREOF, I Robert Lee Truax .Jr. the Father of the Child Bobbie Michelle Truax set my signature below. UJ-~_. ROBERT LEE TRUAX R o~ I Jq~8 DATE I Sworn to and subscribed MY COMMISSION EXPIRES: My Comm ' ISSIOO E~PUBS 2-23-2000 NOV 0 6 1995f/!J To ~~oever is the Court Administrator for the Court of Common Pleas of Cumberland County, Pennsylvania, at One Courthouse Square, Carlisle, Pennsylvania 17013; Mary Michele Meka (also known as Mary Michele Interisno, Mary Michele Truax, and Mary Michele Lindsey) the Mother of the Child Bobbie Michelle Truax at 42 West Locust Street, Mechanicsburg, Pennsylvania 17055; and Whomever Else It May Concern: Regarding the Child Bobbie Michelle Trusx who wss born in Shelby County, Tennessee, on July 18, 1984, and her parents Mary Michele Meka (also known as Mary Michele Interiano, Mary Michele Truax, and Mary Michele Lindsey) and Robert Lee Trusx Jr. in Case Number 97-1401 Civil Term in the Court of Common Pleas of Cumberland County, Pennsylvania: This is a reminder of the notificati~n made on October I, 1998, to Mary Michele Meka (also known as Mary Michele Interiano. Mary Michele Truax, and Mary Michele Lindsey) the Mother of the Child Bobbie Michelle Truax that she Mary Michele Meka (slso known as Mary Michele Interiano, Mary Michele Truax, and Msry Michele Lindsey) the Mother of the Child Bobbie Michelle Truax is to send the Child Bobbie Michelle Truax on Wednesday November 25, 1998, and again on Wednesday December 23, 1998, to visit me Robert Lee Truax Jr. the Father of the Child Bobbie Michelle Truax. This is also a reminder that because Mary Michele Meka (also known as Mary Michele Interiano, Mary Michele Truax, and Mary Michele Lindsey) the Mother of the Child Bobbie Michelle Truax did not allow me Robert Lee Truax Jr. the Father of the Child Bobbie Michelle Truax to pick up my daughter Bobbie Michelle Truax at 42 West Locust Street, Mechanicsburg, Pennsylvania 17055, on June II, 1998, as provided by and in accordance with an Order of the Court of Common Pleas of Cumberland County, Pennsylvania, dated April 28, 1997, the responsibility and expense of providing transportation for the Child Bobbie Michelle Truax to visit me her father Robert Lee Truax Jr. rests solely with the Mother Mary Michele Meks (also known ss Mary Michele Interiano, Mary Michele Truax, and Mary Michele'Lindsey), and the responsibility and expense of providing transportation for the Child Bobbie Michelle Truax to return to her mother Mary Michele Meka (also known as Mary Michele Interiano, Mary Michele Trusx, and Mary Michele Lindsey) rests solely with me the Father Robert Lee Truax Jr. Thus it is Mary's responsibility to determine by what mode of transportation Bobbie is to travel, and it is Mary's responsibility to purchsse and to psy for a one-way ticket to get Bobbie to me on Wednesday November 25, 1998, and again on Wednesday December 23, 1998; it is my responsibility to purchase and to pay for a one-way ticket to get Bobbie back to Mary on Monday November 30, 1998, and again on Sunday January 3, 1999. IN TESTIMONY AND WITNESS WHEROF, I Robert Lee Truax Jr. the Father of the Child Bobbie Michelle Truax set my signature below. tJJ k lirr/. ROBERT LEE TRUAX n~:< 1998 DATE j this thed day of ~a\J ,1998. ~U~ NOTARY PUBLI Sworn to and subscribed before me MY COMMISSION EXPIRES: ~ 'OMMISSIQft EXPIRES SEPT. 18,2002 ~ \ To Whoever Is the Court ndministrator for the Court of Common Pleas of Cumberland County, Pennsylvania, at One Courthouse Square, Carlisle, Pennsylvania 17013, Mary Michele Maka (also known as Mary Michele Interiano, Mary Michele Truax, and Mary Michele Lindsey) the Mother of the Child Bobbie Michelle T~uax at 42 West Locust Street, Mechanicsburg, Pennsylvania 17055, and Whomever Else It May Concern: Regarding the Child Bobbie Michelle Truax who was born in Shelby County, Tennessee, on July 18, 1984, and her parents Mary Michele Meka (also known as Mary Michele Interiano, Mary Michele Truax, and Mary Michele Lindsey) and Robert Lee Truax Jr. in Case Number 97-1401 Civil Term in the Court of Common Pleas of Cumberland County, Pennsylvania. Mary Michele Meka (also known as Mary Michele Interiano, Mary Michele Truax, and Mary Michele Lindsey) the Mother of the Child Bobbie Michelle Truax has not let me Robert Lee Truax Jr. the Father of the Child Bobbie Michelle Truax have any visitation time at all with my daughter Bobbie Michelle Truax during the past one year and three months from September 1, 1997, through and including today December 1, 1998, even though for each and every month since February 1987 I Robert Lee Truax Jr. the Father of the Child Bobbie Michelle Truax can account for the child support payments made by me Robert Lee Truax Jr. the Father of the Child Bobbie Michelle Truax for my daughter Bobbie Michelle Truax at the rate of $175.00 a month. This is a reminder of the notification made on October 1, 1998, and again on November 2, 1998, to Mary Michele Meka (also known as Mary Michele Interiano, Mary Michele Truax, and Mary Michele Lindsey) the Mother of the Child Bobbie Michelle Truax that she Mary Michele Meka (also known as Mary Michele Interiano, Mary Michele Truax, and Mary Michele Lindsey) the Mother of the Child Bobbie Michelle Truax is to send the Child Bobbie Michelle Truax on WedneSday December 23, 1998, to visit me Robert Lee Truax Jr. the Father of the Child Bobbie Michelle Truax. This is also a reminder that because Mary Michele Meka (also known as Mary Michele Interiano, Mary Michele Truax, and Mary Michele Lindsey) the Mother of the Child 80bbie Michelle Truax did not allow me Robert Lee Truax Jr. the Father of the Child Bobbie Michelle Truax to pick up my daughter Bobbie Michelle Truax at 42 West Locust Street, Mechanicsburg, Pennsylvania 17055, on June 11, 1998, as provided by and in accordance with an Order of the Court of Common Pleas of Cumberland County, Pennsylvania, dated April 28, 1997, the responsibility and expense of providing transportation for the Child Bobbie Michelle Truax to visit me her father Robert Lee Truax Jr. rests solely with the Mother Mary Michele Meka (also known as Mary Michele Interiano, Mary Michele Truax, and Mary Michele Lindsey), and the responsibility and expense of providing transportation for the Child Bobbie Michelle Truax to return to her mother Mary Michele Meka (also known as Mary Michele Interiano, Mary Michele Truax, and Mary Michele Lindsey) rests solely with me the Father Robert Lee Truax Jr. Thus it is Mary's responsibility to determine by what mode of transportation Bobbie is to travel, and it is Mary's responsibility to purchase and to pay for a one-way ticket to get Bobbie to me on Wednesday December 23, 19~8, it is my responSibility to purchase and to pay for a one-way ticket to get Bobbie back to Mary on Sunday January 3, 1999. IN TESTIMONY AND WITNESS WHEREOF, I Robert Lee Truax Jr. the Father of the Child Bobbie Michelle Truax set my signature below~ ~E~2i;~f j)~II~q~ DATE , this the /ffday of /Jpumkr, 1998. Sworn to and subscribed before me e-hl4-1z b-~t7'1 NOTARY PUBLIC 1 MY COMMISSION EXPIRES. 1W-~aB8ION EXPIRES Il.. "'tr IIOOa " ~ ~ ,-;~, . " \ ,:,';, \ Mae'Ai L(( T~;TA. . 1.%41 ADC~CAe(~__..AAKhlA'i I\JDA1J,}\"~~ 1'1-", COR.OOVA Tt.tJtJ'F.SS(! 390/8 I - - \ . -- .- - .. .....- -- .-- - , " "-" - c.oul\T AOM//JISTAAT1>A. c.WA.T DF C.OMMl)fJ PleAS of CUM~eALAIO() c.oVNTY ONl. c/)L)A.THoIJS€ s~ lJAA E' C.AA.L1Slt Pf.tV/lJsyL. vANIA 1')0/3 I '. li.;;""~"""-ia;i~.---~"j"'"---""~'-~"--~""'""~'',",'~')'''''''''''''''''''..","""'$'"" ," '\"Q'\,~"~~'J:,2. \,"\\1,"1\\,"",1\"\1",\1,"\1",\,\"\,11\"11I,\1\".\1 -- ROBERT LEE TRUAX JR. 766 ROCKCREEK PARKWAY NORTH ORDOVA, TENNESSEE 38018 ,e , .' ' ..... - - .-~-,.~.- (' ; ,\ ,I ,I .,.' . , , ..... I' / .na.. ..--..--/ .......~<. COURT ADMINISTRATOR FOR THE COURT OF COMMON PLEAS OF CUMBERLAND CO., PA ONE COURTHOUSE SQUARE CARLISLE, PENNSYLVANIA 17055 \'?O\,,-""~~ 02. '",/"","'"""""1'",1'",/"""'1,1,/1'",,,,"'",/1 .~ -~--i"';;';'.-~~~~~~:'iiil '-''I'' ,.-.... . "'"7"'4~""",,,"""'''i,,"''''=+~''-~-,~_'''''_'''_'''i'''''''"''''''~~~~~';'1\i.:Y-frT'ii."~--'--~-n:n To Whoever Is the Court Administrator for the Court of Common Pleas of Cumberland County, pennsylvania, at One Courthouse Square, Carlisle, Pennsylvania 17013, Mary Michele Meka (also known as Mary Michele Interiano, Mary Michele Truax, and Mary Michele Lindsey) the Mother of the child Bobbie Michelle Truax at 42 West Locust Street, Mechanicsburg, Pennsylvania 17055, and Whomever Else It May Concern. Regarding the Child Bobbie Michelle Truax who was born in shelby County, Tennessee, on July 18, 1984, and her parents Mary Michele Meka (also known as Mary Michele Interiano, Mary Michele Truax, and Mary Michele Lindsey) and Robert Lee Truax Jr. in Case Number 97-1401 Civil Term in the Court of Common Pleas of Cumberland County, Pennsylvania. Mary Michele Meka (also known as Mary Michele Interiano, Mary Michele Truax, and Mary Michele Lindsey) the Mother of the Child Bobbie Michelle Truax nas not let me Robert Lee Truax Jr. the Father of the Child Bobbie Michelle TrUax have any visitation time at all with my daughter Bobbie Michelle Truax for over one year and four months since september 1, 1997, through and inclUding today January 8, 1999, including any visitation time at all during the Thanksgiving season of 1997, the Christmas season of 1997, the summer of 1998, the Thanksgiving season of 1998, and the Christmas season of 1998, as well as any visitation time at all as authorized by any of the following: The Circuit Court of Tennessee for the Thirtieth Judicial Circuit at Memphis/ The Amendment Agreement signed in May 1996 by both Mary Michele Meka (also known as Mary Michele Interiano, Mary Michele Truax, and Mary Michele Lindsey) the MOther of the Child Bobbie Michelle TrU3X and Robert Lee Truax Jr. the Father of the Child Bobbie Michelle Truax/ and The Court of Common Pleas of Cumberland county, Pennsylvania. After the MOther Mary Michele Meka (also known as Mary Michele Interiano, Mary Michele Truax, and Mary Michele Lindsey) failed to facilitate the Child Bobbie Michelle Truax visiting the Father Robert Lee Truax Jr. during the Thanksgiving season of 1997 and the Christmas season of 1997, both the MOther Mary Michele Meka (also known as Mary Michele Interiano, Mary Michele Truax, and Mary Michele Lindsey) and Thomas E. Chef fins the Court Administrator at One Courthouse Square, Carlisle, PennsylvanIa 17013, ~'..!:e notified on January 5, 1998, by the Father Robert Lee Truax Jr. that "Another failure by Mary to facilitate Bobbie visiting Robert will result in a forfeiture of child support payments." Both the Mother Mary Michele Meka (also known as Mary Michele Interiano, Mary Michele Truax, and Mary Michele Lindsey) and Thomas E. Cheffins the Court Administrator at One Courthouse Square, Carlisle, Pennsylvania 17013, were notified on January 5, 1998, by the Father Robert Lee Truax Jr. that "Savings bonds equivalent in value to child support payments for the Child Bobbie Michelle Truax which are forfeited by her mother . and not paid by her father . . . will be purchased by him and set aside for him to give Bobbie after July 18, 2002 (her eighteenth birthday)." The Father Robert Lee Truax Jr. requested the Court of Common Pleas of Cumberland County, Pennsylvania, on May 1, 1998, to have a law enforcement officer present at 42 West Locust Street, Mechanicsburg, Pennsylvania 17055, by 4:00 PM EDST on Thursday June 11, 1998, in order to facilitate the exchange of physical custody of the Child Bobbie Michelle Truax from the MOther to the Father at 4,00 PM EDST on Thursday June 11, 1998. IN TESTIMONY AND WITNESS WHF.RF.nF, l Pob..rt Lee Truax Jr. the F~ther o~ the Child Bobbie Michelle Truax set my signature below. lJ&j&W. ROBERT LEE TRUAX cr ~? IH~ TE I Sworn to and subscribed before me 1999. r EB 11 1999 ') t To Whoever Is the Court Administrator for the Court of Common Pleas of Cumberland county, Pennsylvania, at One Courthouse Square, Carlisle, Pennsylvania 17013, Mary Michele Meka (also known as Mary Michele Interiano, Mary Michele Truax, and Mary Michele Lindsey) the Mother of the child Bobbie Michelle Truax at 42 West Locust Street, Mechanicsburg, Pennsylvania 17055, and Whomever Else It May Concern: Regarding the Child Bobbie Michelle Truax who was born in shelby County, Tennessee, on July 18, 1984, and her parents Mary Michele Meka (also known as Mary Michele Interiano, Mary ~ichele..~x, and Mary Michele Lindsey) and Robert Lee Truax Jr. in Case Numb~97-1401 ~vil Term in the Court of Common Pleas of Cumberlend County, Pennsylvania, The Court of Common Pleas of Cumberland County, Pennsylvania, did not have a law enforcement officer present at 42 West Locust Street, ------ Mechanicsburg, Pennsylvania 17055, at 4:00 PM EDST on Thursday June 11, 1998, even though I Robert Lee Truax Jr, the Father of the Child Bobbie Michelle Truax had requested the Court of Common Pleas of Cumberland County, Pennsylvania, on May 1, 1998, to have a law enforcement officer present at 42 West Locust Street, Mechanicsburg, Pennsylvania 17055, by 4:00 PM EDST on Thursday June 11, 1998, in order to facilitate the exchange of physical custody of the Child Bobbie Michelle Truax from the Mother Mary Michele Meka (also known as Mary Michele Interiano, Mary Michele Truax, and Mary Michele Lindsey) to the Father Robert Lee Truax Jr. at 4:00 PM EDST on Thursday June 11, 1998, seeing as how the Mother Mary Michele Meka (also known as Mary Michele Interiano, Mary Michele Truax, and Mary Michele Lindsey) had not let the Father Robert Lee Truax Jr. have any visitation time at all with his daughter Bobbie Michelle Truax during the Thanksgiving season of 1997 and the Christmas season of 1997 as provided by and in accordance with Orders of the Court of Common Pleas of Cumberland county, Pennsylvania even though the fact of the Mother's failure to let the Father have any visitation time at all with the Child during the Thanksgiving season of 1997 and the Christmas season of 1997 as provided by and in accordance with Orders of the Court of Common Pleas of CUmberland County, Pennsylvania was brought to the attention of the Court of Common Pleas of Cumberland County, Pennsylvania on December 1, 1997, and December 2, 1997, and January 5, 1998, and January A, 1998, an1 Janua~l 21, 1998, and February 5, 1998, March 5, 1998, and March 6, 1998, and April 7, 1998, and May 11, 1998. The Mother Mary Michele Meka (also known as Mary Michele Interiano, Mary Michele Truax, and Mary Michele Lindsey) failed on Thursday June 11, 1998, to facilitate the Child Bobbie Michelle Truax visiting the Father Robert Lee Truax Jr.--thereby resulting in a forfeiture of child support payments for which savings bonds equivalent in value to child support payments for the Child Bobbie Michelle Truax (minus offsets of child support payments which qndergo offsets) which are forfeited by the Mother Mary Michele Meka (also known as Mary Michele Interiano, Mary Michele Truax, and Mary Michele Lindsey) and not paid by the Father Robert Lee Truax Jr. are to be purchased by the Father Robert Lee Truax Jr. and set aside for him to give his daughter Bobbie Michelle Truax after July IB, 2002 (her eighteenth birthday) . IN TESTIMONY AND WITNESS WHEREOF, I Robert Lee Truax Jr. the Father of the Child Bobbie Michelle Truax set my signature below. ~t:J!:hJ !~ I; /q91 Sworn to and subscribed before me this the L day of rlil3~ulIR.'1, 1999. ~ MY COMMISSION EXPIRES: _Cnl[' . 1-'_',_ .- .. To Whoever Is the Court ndministrator for the Court of Common Pleas of Cumberland County, Pennsylvania, at One Courthouse Square, carlisle, Pennsylvania 17013, Mary Michele Meka (also known as Mary Michele Interiano, Mary Michele Truax, and Mary Michele Lindsey) the Mother of the Child Bobbie Michelle Truax at 42 West Locust Street, Mechanicsburg, Pennsylvania 17055, and Whomever Else It May Concern: Regarding the child Bobbie Michelle Truax who was born in Shelby county, Tennessee, on July 18, 1984, and her parents Mary Michele Meka (also known as Mary Michele Interiano, Mary Michele Truax, and Mary Michele Lindsey) and Robert Lee Truax Jr. in Case Number 97-1401 Civil Term in the Court of Common pleas of Cumberland County, Pennsylvania. The-savings bonds purchased on July 17, 1998, by me the Father Robert Lee Truax Jr. with the $175.00 forfeited by the Mother Mary Michele Meka (also Known lS Mary M1ct.ele Interiano, Mary Michele Truax, and Mary Michele Lindsey) as child support payment for the Child Bobbie Michelle Truax for the month of July 1998 arrived in July 1998. The savings bonds purchased on August 17, 1998, by me the Father Robert Lee Truax Jr. with the $175.00 forfeited by the Mother Ma1Y Michele Meka (also known as Mary Michele Interiano, Mary Michele Truax, and Mary Michele Lindsey) as child support payment for the Child Bobbie Michelle Truax for the month of August 1998 arrived in September 1998. The savings bonds purchased on ~eptember 15, 1998, by me the Father Robert Lee Truax Jr. with the $175.00 forfeited by the Mother Mary Michele Meka (also known as Mary Michele Interiano, Mary Michele Truax, and Mary Michele Lindsey) as child support payment for the Child 80bbie Michelle Truax for the month of September 1998 arrived in September 1998. The savings bonds purchased on October 15, 1998, by me the Father Robert Lee Truax Jr. with the $175.00 forfeited by the Mother Mary Michele Meka (also known as Mary Michele Interiano, Mary Michele Truax, and Mary Mi~hele Lindsey) as child support payment for the Child Bobbie Michelle Truax for the month of October 1998 arrived in October 1998. The savings bonds purchased on November 13, 1998, by me the Father Robert Lee Truax Jr. with the $175.00 forfeited by the Mother Mary Michele Meka (also known as Mary Michele Interiano, Mary Michele Truax, and Mary Michele Lindsey) as child support payment for the Child Bobbie Michelle Truax for the month of November 1998 arrived in November 1998. However, the savings bonds purchased on December 18, 1998, by me the Father Robert Lee Truax Jr. with the $175.00 forfeited by the Mother Mary Michele Heka (also known as Mary Michele Interiano, Mary Michele Truax, and Mary Michele Lindsey) as child support payment for the Child Bobbie Michelle Truax for the month of December 1998 did not arrive until February 1999. I the Father Robert Lee Truax Jr. thus felt compelled to establish an alternative to my purchasing more savings bonds--unsure as to their arrival at all, let alone when--as a means by which the Child Bobbie Michelle Truax might receive funds forfeited by the Mother Mary Michele Moka (also known as Mary Michele Interiano, Mary Michele Truax, and Mary Michele Lindsey) as child support payment for the Child Bobbie Michelle Truax. The Mother Mary Michele Me!tn ~also kno~'':'1 as Mnrj' rt~~hele !l'it6~iano, Mary Michele Truax, and Mary Michele Lindsey) did not send the Child Bobbie Michelle Truax to visit her dying Grandfather Robert Lee Truax Sr. who died on March 15, 1999, nor did the Mother Mary Michele Meka (also known as Mary l~ichele Interiano, Mary Michele Truax, and Mary Michele Lindsey) send the Child Bobbie Michelle Truax to attend the funeral of her deceased Grandfather Robert Lee Truax Sr. on March 19, 1999 (the date of the funeral service as well as the date of interment). This is notification to Mary Michele Meka (also known as Mary Michele Interiano, Mary Michele Truax, and Mary Michele Lindsey) the Mother of the Child Bobbie Michelle Truax that she the Mother of the Child Bobbie Michelle Truax is lo send the Child Bobbie Michelle Truax on WedneSday June 9, 1999, to visit me Robert Lee Truax Jr. the Father of the Child Bobbie Michelle 1 r' .. 2 Truax. This is a reminder to Mary Michele Meka (also known as Mary Michele Interiano, Mary Michele Truax, and Mary Michele Lindsey) the Mother of the Child Bobbie Michelle Truax that it is her responsibility to determine by what mode of transportation the child Bobbie Michelle Truax is to travel. Mary Michele Meka (also known as Mary Michele Interiano, Mary Michele Truax, and Mary Michele Lindsey) the Mother of the Child Bobbie Michelle Truax is to let me Robert Lee Truax Jr, the Father of the Child Bobbie Michelle Truax know by way of a telephone call from her to me at (901) 388-6656 on Wednesday June 2, 1999, between 8.00 AM EDST and 4:00 PM EDST as to what mode of transpo~tation she has determined the child Bobbie Michelle Truax is to travel. This is a reminder to Mary Michele Meka (also known as Mary Michele Interiano, Mary Michele Truax, and Mary Michele Lindsey) the Mother of the Child Bobbie Michelle Truax that it is her responsibility to purchase and to pay for a one-way ticket to get the child Bobbie Michelle Truax to me Robert Lee Truax Jr. the Father of the Child Bobbie Michelle Truax on Wednesday June 9, 1999. Transportation costs and lodging costs I Robert Lee Truax Jr. the Father of the Child Bobbie Michelle Truax incur in efforts to facilitate visitation beginning on Wednesday June 9, 1999, or thereafter between the Child Bobbie Michelle Truax and myself will be utilized as offsets to child support payments forfeited by Mary Michele Meka (also known as Mary Michele Interiano, Mary Michele Truax, and Mary Michele Lindsey) the Mother of the Child Bobbie Michelle Truax. If Mary Michele Meka (also known as Mary Michele Interiano, Mary Michele Truax, and Mary Michele Lindsey) the Mother of the Child Bobbie Michelle Truax sends the Child Bobbie Michelle Truax on Wednesday June 9, 1999, to visit me Rebert Lee Truax Jr. the Father of the Child Bobbie Michell.. Truax, it is my responsibility to purchase and to pay for a one-way ticket to get the child Bobbie Michelle Truax back to Mary Michele Meka (also known as Mary IUchele Interiano, Mary Michele Truax, and Mary Michele Lindsey) before Wednesday sept~mber 1, 1999. In the event that the child Bobbie ~Iichelle Truax does not have actual visitation time with me her father Robert Lee Truax Jr. on the second F1iday in June 1999 the chlld eupport payment for the month of January 1999 forfeited by the ~.other I'.ary Michele Meka (also known as ~lary Michele Interiuno, Mary Michele Truax, and Mary Michele Lindsey) will underglll an offset of $],75.00, whereas if the Child Bobbie Michelle Truax does have actlJal visitation time with me her father Robert Lee Truax Jr. on the second Friday in June 1999 I the E'athel' p.obert Lee Trua,: Jr. will give the Child Bobbie Michelle Truax $175.00--$175.00 being the amount forfeited by the Mother Mary ~lichele Meka (also known as'Mary Michele Interiano, Mary I'J.chele Truax, and Mary Micliele Lindsey) as child support payment for the month of January 1999. IN TEST1MONY AND WITNESS WHERJ::Or, I Robert Lee Truax Jr. the Father of the Child Bobbie Michelle Truax set my signature balow. w ~O-~ ~ ROBERT LEE TRUAX R4 7fl,:? 3. /rq~ DATE I .:< I'd Sworn to and subscribed before IIIe this the."J-': day of- , 1999. MY COMMISSION EXl'IRES. MV COMMISSIOl'lt:xrl/lF.:S, Janu:1r\' I~ ,n", . .' . JUN - 4 199~O , , . To Whoever 16 the Court AdmInistrator for the Court of Common Pleas of Cumberland County, Pennsylvania, at One Courthouse Square, Carlisle, Pennsylvania 17013; ~Iary Hichele Meka (also known as Mary Michele Interiano, Mary Michele Truax, and Mary Michele Lindsey) the Mother of the Child Bobbie Michelle Truax at 42 West Locust Street, Mechanicsburg, Pennsylvania 17055; and Whomever Else It May Concern: Regarding the Child Bobbie Michelle Truax who was born in Shelby County, Tennessee, on July 18, 198/" and her parents Mary Michele Meka (!Ilso known as Mary Michele Interiano, Mary Michele Truax, and Mary Michele Lindsey) and Robert Lee Truax Jr. in Case Number 97-1401 Civil Term in the Court of Common Pleas of Cumberland County, Pennsylvania: This is a reminder that the savings bonds purchased on December 18, 1998, by me the Father Robert I.ee Truax Jr. with the $175.00 forfeited by the ~(other Mary Hichele Meka (also known ,as Mary Michele Interiano, Mary Michele Truax, and Mary Michele Lindsey) as child support payment for the Child Bobbie Michelle Truax for the month of December 1998 did not arrive until February 1999. I the Father Robert Lee Truax Jr. thus felt compelled to establish an alternative to my purchasing more ssvings bonds--unsure as to their srrival at all, let alone when--as a means by which the Child Bobbie Michelle Truax might receive funds forfeited by the.Mother Mary Michele Meka (also known ss Mary Michele Interiano, Mary Michele Truax, and Mary Michele Lindsey) as child support psyment for the Child Bobbie Michelle Truax. This is a reminder that the Mother Mary Michele Meka (also known as Mary Michele Interiano, Mary Michele Truax, and Mary Michele Lindsey) did not send the Child Bobbie Michelle Truax to visit her dying Grandfather Robert Lee Trusx Sr. who died on March IS, 1999, nor did the Mother Mary Michele Meka (also known as Mary Michele Interiano, Mary Michele Trusx, and Mary Michele Lindsey) send the Child Bobbie Michelle Truax to attend the funeral of her deceased Grandfather Robert Lee Truax Sr. on March 19, 1999 (the date of the funeral service as well as the date of interment). This is notification that Mary Michele Meka (slso known as Mary Michele Interiano, Mary Michele Truax, and Mary Michele Lindsey) the Mother of the Child Bobbie Michelle Truax was notified by me Robert Lee Truax Jr. the Father of the Child Bobbie Michelle Truax to send the Child Bobbie Michelle Truax on Wednesday June 9, 1999, to visit me Robert Lee Truax Jr. the Father of the Child Bobbie Michelle Truax in that Mary Michele Meka (also known as Mary Michele Interiano, Mary Michele Truax, and Mary Michele Lindsey) the Mother of the Child Bobbie Michelle Truax was notified on May 3, 1999, by me Robert Lee Truax Jr. the Father of the Child Bobbie Michelle Truax. This is s reminder that transportation costs and lodging costs I Robert Lee Truax Jr. the Father of the Child Bobbie Michelle Truax incur in efforts to fscilitate visitation beginning on Wednesday June 9, 1999, or thereafter between the Child Bobbie Michelle Truax and myself will be utilized as offsets to child support payments forfeited by Mary Michele Meka (also known as Mary Michele Interiano, Mary Michele Truax, and Msry Michele Lindsey) the Mother of the Child Bobbie Hichelle Truax. This is a reminder that if Mary Michele Meka (also known as Msry Michele Interiano, Mary Michele Truax, and Mary Michele Lindsey) the Mother of the Child Bobbie Hichelle Truax sends the Child Bobbie Michelle Truax on Wednesday June 9, 1999, to visit me Robert Lee Truax Jr. the Father of the Child Bobbie Michelle Truax, it is my responsibility to purchase and to pay for a one-way ticket to get the Child Bobbie Michelle Truax back to Mary Michele Meka (also known as Mary Michele Interiano, Mary Michele Truax, and Mary Michele Lindsey) before Wednesday September I, 199~. In the event that the Child Bobbie Michelle Truax does not have actual visitation time with me her father Robert Lee Truax Jr. on the second Friday in June 1999 the child support payment for the month of Janusry 1999 forfeited by the Mother Mary Michele ~(eka (also known as Mary Michele Interiano, Mary Michele Truax, and Mary Michele Lindsey) will undergo an offset of $175.00, whereas if the Child Bobbie Michelle Truax does have actual visitation time with me her father Robert Lee Truax Jr. on the second Friday in June 1999 I the Father Robert Lee Truax Jr. will give the Child BoBbie Michelle Truax $175.00--$175.00 being the amount forfeited by the Mother Mary 1 ",." '.... 2 Hiche1e Hekn (n1so knOlm ns Hary HIche1e Interiano, Hnry Hichele Truax, and Hary Hichele Lindsey) ns child support pnyment for the month of January 1999. In the event that the Child Ilohbie Hichelle Truax does not hove actual visitation time with me her fnther Robert Lee Trunx Jr. on the ~hird Friday in June 1999 the child support pnyment for the month of February 1999 forfeited by the Hother Hnry HIche1e Hekn (n1so known os Hary Hichele Interillno, Hary Hiche1e Trunx, nnd Hary Hichele Lindsey) will undergo on offset of $175.00, whereas if the Child Bobble Hlchelle Truax does hove actual visitation time with me her father Robert Lee Truax Jr. on the third Friday in June 1999 I the Father Robert Lee Truax Jr. will give the Child Bobbie Hichelle Truax $175.00--$175.00 beinr, the nmount forfeited by the Hother Hary Hichele Heka (lIlso known liS ~Inry Hichele Interiano, Mary Hichele Truax, and Hary Hichele Lindsey) os child support pnyment for the month of February 1999. In the event thnt the Child Ilobbie Hichelle Truax does not hove actual visitation time with me her fnther Robert Lee Truax Jr. on the fourth Friday in June 1999 the child support payment for the month of March 1999 forfeited by the Hother Hary Hlchele Heka (also known os Mary Michele Interiano, Hary t1ichele Truax, and Hary Hichele Lindsey) will undergo an offset of $175.00, whereas if the Child Bobbie Michelle Truax does have actual visitation time with me her father Robert Lee Truax Jr. on the fourth Friday in June 1999 I the Father Robert Lee Truax Jr. will give the Child jlobbie Hichelle Truax $175.00--$175.00 being the amount forfeited by the Mother Mary Michele Meka (also known as Hary Hichele Interiano, Mary Michele Truax, and Mary Michele Lindsey) as child support payment for the month of March 1999. In the event that the Child Bobbie Hichelle Truax does not have actual visitation time with me her father Robert Lee Truax Jr. on the first Friday in July 1999 the child suppor~ payment for the month of April 1999 forfeited by the Hother Hary Hichele'Heka (also known as Hsry Michele Interiano, Mary Hichele Truax, and Hary Michele Lindsey) will undergo an offset of $175.00, whereas if the Child Bobl:1ie Michelle Truax does have actual visitation time with me her father Robert Lee Truax Jr. on the first Fridsy in July 1999 I the Father Robert Lee Truax Jr. will give the Child Bobbie Michelle Truax $175.00--$175.00 being the amount forfeited by the Hother ~Iary Michele Heka (also known as Mary Hichele Interiano, Hary Michele Truax, and Mary Michele Lindsey) as child support payment for the month of April 1999. In the event that the Child Bobbie Hichelle Truax does not have actual visitation time with me her father Robert Lee Truax Jr. on the second Friday in July 1999 the child support payment for the month of Msy 1999 forfeited by the Mother Hary Michele Heka (also known as Mary Michele Interiano, Hary Michele Truax, and Hary Michele Lindsey) will undergo an offset of $175.00, whereas if the Child Bobbie Michelle Truax does have actual visitation time with me her father Robert Lee Truax Jr. on the second Fridsy in July 1999 I the Father Robert Lee Truax Jr. will give the Child Bobbie Hichelle Truax $175.00--$175.00 being the amount forfeited by the Mother Msry Hichele Meka (also known as Hary Michele Interiano, Mary Michele Truax, and Hary Hichele Lindsey) as child support payment for the month of May 1999. Relative to the five (5) paragraphs immediately preceding this paragraph, the total amount of money to be given to the Child Bobbie Michelle Truax by me her father Robert Lee Truax Jr, will be available to be given to her during her visitation time with me at n rate of one-seventh (1/7) per day on each of these seven (7) days: the third Friday in July 1999, the fourth Friday in July 1999, the fifth Friday in July 1999, the first Friday in August 1999, the second Friday in August 1999, the third Friday in August 1999, and the fourth Friday in August 1999. IN TESTU10NY AND WITNESS WHEREOF, I Robert Lee Truax Jr. the Fsther of the Child Bobbie Hichelle Truax set my signature below. JJJ:lu ~ ,. it LTE'. Ij /9?9 ROBERT LEE T~~~ ~ Sworn to and subscribed before me this the Icl day o~. { 1999. MY COMMISSION EXPIRES: MY COMMISSION EXPIRES NOV. 21, 2000 ,- SEP 2 II 199~ ..,MARYMICHElE LINDSEY: IN THE Cbun OFCDMM.OJ\LfLE~~QF__ .... ..._..Plqitlt.-tf ,. ) : CUMBERLAND, CDUNI~JENNSIL~ANJA --.---._-.".,.yS, : CIVIL ACTIDN...LAJi________._ ~JM!RL_lEf,JROAXJ JA.) :__ --___'___h.._. .____.DdeVlJcUlt.: ND.j1-I~OLCJVJL,JERt1 flIDtJUQ~f:.;r.lJesler Ole.) Jr. .._ '.,__, ---- -_.,-~....._,----_..- -.'-- ~. . ~._. .M.... _.___.H'.. 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""-..-I!- - _._.._______m__.. - -. ... - ..-.....--.-..---...--...----.- ii " ."'. __'M_~'.__'_ _....___.~.u_..__._.___.__.~_.__".~.. ._. . .,..,_,',. _,____......+__..M_.._.___._"...___________._ ii 11 - --'.' -_.' .,_._.t-.--""_.~._----,--- .---- .~ ," ..--.--.--.....,.- -~". .----~-..-.-~~_._.--_. t' , t . __... .1..___ . _ _ .______...~n___U.._.._ i " i: ,. .- ._. .... .-----------_._-0-------.--.-- ..__._ _._.;.,> 1- ,- MARY MICHELE LINDSEY, . IN THE OOURT OF CXlMMON PLEAS OF . Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA . . . : vs. . NO. 97-1401 CIVIL TERM . . . ROBERT LEE TRUAX, JR., . CIVIL ACTION - LAW . Defendant . CUSTODY/VISITATION . PRIClt JUDGE: J. WeBley Oler, Jr. aJS'l'an CXH:ILIATIOO SlHlAm( REPCm.' IN ACXXIUlANCE Wl'l'H <nmERLAND 00Nl'l( RULE OP CIVIL 1'lU..1SIJlJRE 1915.3-8, the undersigned CUstody Conciliator submits the following report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OP Bml'B <DRRENl'LY IN aJS'l'an OP Bobbie Michelle Truax July 18, 1984 Mother 2. A Conciliation Conference was held on Novelltler 10, 1999 with the Mother in attendance. The Father, who filed this Petition for Contempt Pro Se, neither attended the Conference nor contacted the Conciliator concerning participation by telephone. The basis for the Father's Petition for Contempt was his allegation that the Mother did not permit him to have his period of summer custody with the Child in 1998. It should be noted that this is the 3rd Petition filed with the Court by the Father, Pro Se, either requesting a Modification to the CUstody Order or a finding of Contempt. The Father resides in Tennessee. Q1 the 3 previous dates (June 12, 1997, February 17, 1998 and Noverrber 10, 1999) on which Conferences were scheduled on the Father's Petitions, the Father did not appear or contact the Conciliator. 3. In light of the Father's failure to pursue the claims raised in his 3 prior Petitions on which CUstody Conciliation Conferences were scheduled, the Conciliator recomnenda that the Court review any future Petitions filed by the Father to determine whether an additional Conference is warranted. The Conciliator submits the attached Order relinquishing jurisdiction in this case. r /V~ (0 /999 ~_..14v-~.J~.~ DATE . Dawn S. Sunday, Ea~'ir'J CUstody Conciliator