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Home My WebLink About06-4658 . . Law Office of John P. Neblett Suite 204 2000 Linglestown Road Harrisburg, PA 17110 717.671.8454 Counsel for Plaintiff Pamela S. Dent tka Pamela S. Bottorf Plaintiff IN THE CUMBERLAND COUNTY COURT OF COMMON PLEAS v. Richard E. Bottorf ~ J n Defendant Case no. b(p- L{(PJ~ ~ PRAECIPE TO ENTER JUDGMENT TO THE CUMBERLAND COUNTY PROTHONOTARY: Per the previously transmitted recgr.ds, please enter judgment in favor of Jr. Pamela S. Dent and against the Richard E. Bottor:t;Jn the amount of$34,373.46. Respectfully submitted, Jo P. eblett ttorney 1.D. No. 80036 Law Office of John P. Neblett 2000 Linglestown Road, Suite 204 Harrisburg, P A 1711 0 717.671.8454 () ~ -uro mrr: -"?" '-r ..:.- ~";: zr- (j) );" -c.... ~, ~c s: (~:. 5>~ ~ r;; g;t :po c: tn ~ ~.~ ~ ~6 ~""l -gr:::u "'0 (0 :JI: m - -'1 ;;, ~ en I , ,Al!,~, 10.,.05 04: 36p (- .. . /;>~,!;s&Bu,..d..n 3862580030 p.3 IN THE CIRCUIT COURT, SEVENTH JUDICIAL CIRCUIT, IN AND FOR FLAGLER COUNTY, FLORIDA IN RE: The Marriage of CASE NO.: 96-752-CA I r,J. ,'.:"'.',':\ -0 '"' ,':,:> ~.J' )> -< ~ (") .." -0 , r r r0- m ~ m ;:0 0 ;:J m " 0 z r- "" 0 f-' m - .J: ~, (") z J -'1 I.'" -l -'0 C) (") ::r: :3 c: 0 m :z c: 0 f-' -l ~;J ~ 1'0 -', -, .." " ORDER c...; r~ PAMELA S. BOTTORF, n/kIa, PAMELA DENT, Petitioner, and RICHARD E. BOITORF, JR., Respondent. THIS CAUSE having come before the Court upon the issues of credits and arrearages pursuant to the Court's Order dated August 3, 200S, and the Court being otherwise fully advised in the premises, it is hereby ORDERED AND ADJUDGED that the Former Husband's current arrearage Iigure for child support is $32,229.39 and his arrearage for previously-ordered costs is $2,144.07 for a total amount of $34,373 .46. A judgment is entered against the Fonner Husband in the amount of of $34,373.46 for which let execution issue. DONE AND ORDERED in Chambers at BunnelJ, Flagler Coun~,(:~ this ~ day ~ _-OfCIl~C(f.\' , 2005. ;~;lJii"'<~ '" ,~..~ ., " : . t1! . . ~ , : . ~ ~ : . .;I ". ~ '. ~.. ......... t'" .. I, COuN1", _-- \\\"",... cc: Leonard R. Ross, Esquire Lauren Koleilat, Esquire STATE OF FLORIDA: COUNTY OF FLAGLER: I, GAIL WADSWORTH, Clerk of the Circuit Court of the Seventh Judicial Circuit of Florida, in and for Flagler County, DO HEREBY CERTIFY that the foregoing is a copy of: Order Dated 9/13/05 in the case of 96-000752CA Bottorf vs Bottorf STATE OF FLORIDA: COUNTY OF FLAGLER: I, RAUL A. ZAMBRANO, one of the Judges of the Circuit Court of the State of Florida, for the Seventh Judicial Circuit, in and for Flagler County, DO HEREBY CERTIFY that the foregoing certificate and attestation by GAIL WADSW said GAIL WADSWORTH, as Cler of 'd State of Florida, in and for Flagler 0 nty, i referred to in the said certificate, a d a same; and is authorized by law to ffi th said GAIL WADSWORTH affixed t t e or seal of said Court thereto affixed i t en Dated at Bunnell, Florida, on thi (Official Seal) STATE OF FLORIDA: COUNTY OF FLAGLER: I, GAIL WADSWORTH, Clerk of the Circuit Court of the Seventh Judicial Circuit Court of the State of Florida, in and for Flagler County, DO HEREBY CERTIFY that RAUL A. ZAMBRANO, who signed the foregoing certificate is one of duty commissioned and qualified Judges of said Court; and that his signature to the foregoing certificate is his genuine signature. 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'--- IN THE CIRCUIT COURT, SEVENTH JUDICIAL CIRCUIT, IN AND FOR FLAGLER COUNTY; FLORIDA CASE NO 96-752-CA PAMELA S. BOTIORF, Petitioner, v. RICHARD E. BOTIORF, JR., Respondent. I ORDER FOR ARREST TO ALL AND SINGULAR THE SHERIFFS OF THE STATE OF FLORIDA GREETINGS THIS is to command you, as you have heretofore been commanded, to take RICHARD E. BOTTORF, JR., if he is found in your County, and deliver him for transportation to the Flagler County Jail where he is to be incarcerated for a period of 90 days. as a consequence oflus contempt in failing to comply with the previous Order of this Court entered herein on November 3, 1999, a copy of which is attached hereto. The Respondeni may purge himself of the said contempt and may be released. from custody by payment to the Clerk of the Court of Flagler County, Child Support Division, the sum of $2,000,00 together with $5.25. Clerk's cost, and prior to release shall also pay $25.00, Sheriff's costs. The Respondent shall further pay prior to release, any costs accrued by the Flagler County , Sheriff or any County Sheriffs office for transportation or otherwise as a result of this order. DONE AND ORDERED m _ " 1'1_ ~" Bmmd1, F.gl~ County, Florida this_ 16th day of February, 2000. _ -W-~ / CIRCUIT JUDGE cc: Richard E. Bottorf, Jr., 405 Wren Court Mechanicsburg, PA 17055 Pamela Bottorf, 19 Putter Drive, Palm Coast, Fl32164 1 Rug .30 05 04:38p , ~ ',. .' . '-... ' P'1ss&Burd.>n 3862580030 p.9 ;., / / IN j:lJE ClRCLilI WUB..f, ':;hV.bNIH JUDICIAL CIRCUIT, IN' AND FOR FLAGLER COUNTY, FLORIDA / I / ,- ./ / CASE NO.: 96-752-CA PAMELAS. BOTTORF, Petitioner, and RICHARD E. BOTTORF, JR, Respondent. I ORDER FOR CONTEMPT nns CAUSE came before the Court a motion for contempt filed by the Petitioner and motion for continuance filed by the Respondent.. The Petitioner was present fur the hearing; the Respondent was absent, however, he was represented, by Jerome Rotenberg, Esq. The Court having reviewed the motions and heard arguments and evidence of the parties, finds that the Respondent has not paid the court ordered child support. Additionally, this Court finds that the Respondent possesses the ability to pay the amount imposed by the Court, however, he has willfully disregarded this Court's order. THEREFORE, it is hereby ORDERED and ADJUDGED that 1. The motion for continuance is DENIED. 2. Respondent, RICHARD E. BOTTORF, JR. is in contempt of this Court's order to pay child support. He is in arrears in the amount of $17,483.38 as of October 21, 1999. 3. Respondent is to serve ..t2 days in The Flagler County Inmate Facility; such sentence is suspended providing the Respondent purges himself by paying $2,000.00 within 20 days of this order to the Clerk of Court, Post Office Box 787, Bunnell, FL 32110. Said purge shall included the Clerk's fee of 4% or a flat fee of $5.25 which ever is less. Therefore, Respondent shall pay a total of $2,005.25. 4. The purge payment shall be made, pursuant to this Order, by cash, inoncy order, cashiers or certified check. The monies paid in the process of purging may be collected by the Flagler County Sheriff on behalf of the Clerk of the Circuit Court, Rug .~O 05 04:38p , . " . .t..... .: P_'1ss8.Burden 3862580030 p. 10 t-.'Y~ ,~1".,11 in "';',~ll'~'\("'~~ ~- ~ f.__,. .-\.....:'~,....~ .., .,:-1:.:. T"'-"",~..,-,::,:, T"l. L:.!" _,., ~~. ;. ~"" ..,:1..... - .. . ..):.. ,I.. .,1.', ..~, ... .,.: ,. '-') ." ... ,../,...... j~......\,... ~v ~.......... ~l,. ~'......7..'"' .l..'......1~"..1'-'ll..;t l~ ~ . I..:av!.l, r~ J.ltlill two days' of receipt. 5. A judgment is entered against the Respondent in the amount of$17,483.38 for which let execution enter. DONE and ORD~[n Chambers, at the Flagler County Courthouse, in Bunnell, Flagler C'""!y, Pfund"., <': d.yofN""""",,, 1999. ~ it:. . ._~ /Kim C. Hammond CIRCUIT JUDGE cc: Pamela Bottorf 19 Putter Drive Palm Coast, FL n.164 Richard E. 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S jgg. ~~ fA t:l " ""0 !:l 0$ Nt:l .... l"l ~g. ~ ??$ ':1>.... rn 8' tI::l ..... 00 0"0 0'< 8'tI.l W ~ ~. 0.", rB. '" _e. i 00 '" _e. . !! .VI ...... ...... ':I>. 't.. ~ e:l (') i.> 0 ..... ~ ~ .Rug 30 05 04:371" P",ssl!.Burden 3862580030 1".7 ) ><'" ~ '" ><'" >< '-<'-<a::~~'Tl'-< '" ""l '" => =- <:> tog => " <:> .. ~a\>l'82lg.~ <:> => <:> III <:> e: .... d Ul e: "., ., ... ., '" 0'<-: * I: S ~ ~ .. ~ 1:1 Q. Q. Q. Q. > I: ~ ~~~fH~~ O~ '" ... 0\ 0\ 0\ 0\ 0\ 0\ ~~~~~~ cr- t::l'l- 000000000000 i.~ O"d ::s a (') NNNNNN :;:c[ \0\0\0\0\0\0 Jo-I '"""'" _ _ """'" I-oL g p. gbbbbo .. on 00000 ~. l:l <:g 8.0 ::t 00 ,..... l----",..........,....._ i ... wWWwww '" VlVlVlVl~Vl Qc ~~~~~~ '" QO 000000000000 ... .... '" ~ '" t;I:I"t:J P ,fIQ J7' ... Ul '" '" w 8i e!.~ ~ ~ s '" ~ ~. !=' <:> ~ ~ ~ .... ~ ~ w '" '" .... .... ... .... .... f . i ':..! iJ w ~ 00 e '" '$. <:> -..l A. ~ ... ~ = '" - 0'1 -..l 00 UI ... ... ... ... ~ 03 N P ~ ~ w Pi w <II N ~ 0\ :c ~ .... <:> ... ic ... .... .... \C ... 0'1 QO Ul ~ ~ * "d P. J1 -g i:l 0 ::l. 0 n ~ ~. o e!. cr~Cf) t::" .. ~ ",' n ~. ~ 5. g 0 << ::s"d 'i ~ ~j' 9 '"' - g. s. s:~ 8. N N ... ... .- ~ '8 Co ~ "'" (') t co .- Sl ... N ... ... s ~ - ~ i A. '" 00 ~uc 30 05 04:38p i>-".ss&Burden 3862580030 p.8 ." . .---- IN THE CIRCUIT COURT, SEVENTH JUDICIAL CIRCillT, IN AND FOR FLAGLER COUNTY; FLORIDA CASE NO 96-752-CA PAMELA S. BOTTORF, Petitioner, v. RICHARD E. BOTTORF, JR., Respondent. I ORDER FOR ARREST TO ALL AND SINGULAR THE SHERIFFS OF THE STATE OF FLORIDA GREETINGS TIllS is to command you, as you have heretofore been commanded, to take RICHARD E. BOTTORF, JR., if he is found in your County, and deliver him for transportation to the Flagler County Jail where he is to be incarcerated for a period of 90 days, as a consequence ofllis contempt in failing to comply with the previous Order of this Court entered herein on November 3, 1999, a copy of which is attached hereto. The Respondent may purge himself of the said contempt and may be released from custody by payment to the Clerk of the Court of Flagler County, Child Support Division, the sum of $2,000.00 together with $5.25, Clerk's cost, and prior to release shall also pay $25.00, Sheriff's costs. The Respondent shall further pay prior to release, any costs accrued by the Flagler County Sheriff or any County Sherifrs office for transportation or otherwise as a resulto! this order. DONE AND ORDERED in chambers at Flagler County C rthouse, Bunnell, Flagler County, Florida this_ 16'" day of February, 2000. CIRCUIT JUDGE cc: Richard E. Bottorf, Jr., 405 Wren Court Mechanicsburg, PA 17055 Pamela Bottorf. 19 Putter Drive, Palm Coast, F132164 1 Rug 30 05 04:38p P'lssl.Burden 3862580030 p.s .. , o ,', .I / / / Ei'iTill Clli.Ci.JIl COU1'-.1'. .':i1:lVbNHi JUDICIAL CIRCUIT, IN' AND FOR FLAGLER COUNTY, FLORIDA l ,; / / i CASE NO.: 96-752-CA PAMELA S. BOTTORF, Petitioner, and RICHARD E. BOTTORF, JR., Respondent. I ORDER FOR CONTEMPT THIS CAUSE came before the Court a motion for contempt filed by the Petitioner and motion for continuance filed by the Respondent.. The Petitioner was present for the hearing; the Respondent was absent, however, he was represented, by Jerome Rotenberg, Esq. The Court having reviewed the motions and heard arguments and evidence of the parties, finds that the Respondent has not paid the court ordered child support Additionally, this Court finds that the Respondent possesses the ability to pay the amount imposed by the Court, however, he has willfully disregarded this Court's order. THEREFORE, it is hereby ORDERED and ADJUDGED that 1. The motion for continuance is DENIED. 2. Respondent, RICHARD E. BOTTORF, JR. is in contempt of this Court's order to pay child support. He is in arrears in the amount of $17,483.38 as of October 21, 1999. 3. Respondent is to serve -!i2. days in The Flagler County Inmate Facility; such sentence is suspended providing the Respondent purges himself by paying $2.000.00 within 20 days of this order to the Clerk of Court. Post Office Box 787, Bunnell, FL 321 10. Said purge shall included the Clerk's fee of4% or a. flat fee of $5.25 which ever is less. Therefore, Respondent shall pay a total of $2,005.25. 4. The purge payment shall be made, pursuant to this Order, by cash, inoney order, cashiers or certified check. The monies paid in the process of purging may be collected by the Flagler County Sheriff on behalf of the Clerk of the Circuit Court, Rug 30 05 04:38p ~",ss"Burden 3862.580030 p.10 . ~'.~+ dn11 ~rl :,\~(:.h c:~'~;~'::l ~~ "~ ~:-::":""::;:":i:::(;d ~~ th...~ '8('n:;:;:iti~, r....:.E.[iVli:~ Di'.1~i0l~ ...yit~llil two days' of receipt. 5. A judgment is entered against the Respondent in the amount of$17,483.38 for which let execution enter. DONE and ORD~gJn Chambers, at the Flagler County Courthouse, in Bunnell, Flagler Co",,,,, Flori'" tb;, " d., ofN_, 1999. ~~. . ~~C /Kim C. Hammond CIRCUIT ruoGE CC: Pamela Bottorf 19 Putter Drive Palm Coast, FL 3~)64 Richard E. Bottorf; Jr. 405 Wren Court Mechanicsburg, PA 17055 " Rug 30 05 04:39p , p-"'"Iss&Burden 3862580030 p.11 j Social Security Administration Retirement, Survivors and Disability Insurance ....,.. " ,. 1 'l ...\Ol.,H.:e vl ...~\\:<li\i.. Office of Central Operations 1500 Woodlawn Drive Baltimore, Maryland 21241.1500 Date: October 9, 2000 Claim Number: 168-48.3931HC1 PAMELA S 801'roRr FOR l.JNDSA Y MAE BOT'l'ORF 19 PUTl'ER DR PALM COA.ST, FL 32164.7404 1"\1",1.1.,.\1.11...1.,11...1.1.,111,,,,/,,/,..11/,'../,/../ LINDSAY M BOTTORF is entitled to monthly child's benefits beginning March 1999. We have chosen you to be her representative payee. Therefore, you will re<:eive her checks and use the money for her needs. What We Will Pay And When . You will receive $4,172,25 al:ound October 15, 2000. . This is the money LINDSAY is due for MArch 1999 through Septembel' 2000. - . LINDSAY M BOTTORF's next payment of $291.00. which is for October 2000, will be received on 01' about the third Wednesday of November 2000. . After that you willl'eceive $291.00 on or about the third Wednesday of each month. . These and any future payments will go to the financial institution you selected. Please I.et us know if you change your m.ailing addre85, so we can send you letters directly. . Later in this letter, we will show you how we figured these amounts. The day we make payments on tbis recol'd is based on IUCHARD E BOTTORF JR's date of birth. Enclosul'e(s): Pub 05-10076 Pub 05-10077 Pub 05-10075 c ~~'\ --";\>,CUlr \'~E"'UY CERTIFY thl. to b. a true :o(cc..........:~~ correct oopy 01 the orig1nal ;:~..~;.;~ C(f~',I1I:llilJn thisq'ffice. FdJ See Next $,~ -~aielfthIS Day of . 1u. ., I ~ . \ j.,:jJ~o () I,p GAIL WADSWORTH ",'1:.....,. .~~~ ~ . CLERK OF CIRCUIT COURT II:QtE~'C"O~~V .oJ(Jk-- J-flOl.1M D.C '\ ... \\""..... 3 . ..-.- ''''..~ IN 'l'IIE CIRCUIT c:ot1RT OF r...oRIDA SEVENTH JUDICIAL CIRCUIT, IN AND FOR FLAGLER COIlN'l'Y, CIVIL ACTION In Re. CASS NO.. 96-0000752-CA BOTTORF, PAMBLA S Petitioner. In.t No.eeel6417 D&t...7/12/21e1 SYO i~;R Count~ 8~. D, C. n...1S.42:39 ~~~070IpA6E0491 VS. .0. BOT'l'ORF, RI CHARD S 405 WREN CT Ml!:C1MICSBURG, PA 17045 Respondent. Jt1IXlMBNT/CERTIFlCA'1'E OF DBLINQUENCY The undersisp1ed, being the duly authorized and reaponaible local aepository for court-ordered support payments ~suant to F.S. 61.181, in ~G~.~ county hereby certifies that BOTTORF, RICJWlD S has failed to pay into the depository the cQUJ:t-ordered support payment as IIIlIndated bY the current Support Oreler in !:his cause. AS of this date. the tot support arrearage is $8,956.08 balance at te not including any costs or fees. I further certify that BOTTO was issued a Notice of Delinquency 04/29/2000, and thirtr (30) or more dayS hav! elapsed since the del:Lnquent 11<< refe:a:enc aboVe _s due. Pursuant to P.S . tMs Certificate evidences a Final n by operation of law for all past due and future p ts ether with all applicable costs and fees as provided by law for wbleh execution may issue wh s e full force, effect and attributes of a JUdgmen t d by a Court in the State of Florida. Dated this 12th .....l .';".';! , j ';j ': .: .' ,",. ~,~ :.1 " ',.', ';'''"1 .. ~~'! .:~-~;'j '1 .... ~ .:leiif ~l ..... . ,:.;: , 4'.A.. ....."ii;~ t'.ptl:......~"',.,,~ '\\.:-~ CO~ _$'" ~""",........,.; -"'0010" "l~' ~1.10'~..............'.-~ .....~. .. ~ ....---.. -'--~_.~-'~.........;:~...:..,._.;...~,\;..,. . I 2- ~ ~ = :? <:1" ~,f' ~ ~ 7\:.:\ G') ~~ Zt - (f) ,l 8~ ~(- ~ "",) <::: ~) -0 -r:.l' ?;,( :z:. ():tJ ~(-) -,.~ C: - (5 z ~ :<! <..> ~ -' Law Offlce of John P. Neblett Suite 204 2000 UnglestDwn Road Harrisburg, PA 17110 717.671.8454 Counsel for Plaintiff Pamela S. Bottorf Plaintiff IN THE CIRCUIT COURT, SEVENTH OF JUDICIAL CIRCUIT AND FOR FLAGER COUNTY, FLORIDA v. Richard E. Bottorf, iff, Defendant NO. 96-752- CA AFFIDAVIT I, Pamela S. Dent, hereby verify the following: I am the above referenced Plaintiff and my address Is: PO Box 740208 Orange City, FL 32774 -- Jr. The defendant in this case Is Richard E. Bottorf"whose address Is: 810 Sherwood Road New Cumberland, PA 17055 I have a judgment against the defendant that Is valid, enforceable and unsatisfied. I verify that the statements made In this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. ~ 4904 relating to unsworn falsification to authorities. Date: ~ - \ - {J(n \ Pamela S. Dent ~ ~ Q. -o~ ~. ~~ c!)t\ (;') .-o:~. ';?;. - '& '(k';'; sr-. ~-'C ~, ~ ~ 'J1:.~C)' jT\ Q: - ~ ~ ;::, 'l! :2. cI' Law Office of John P. Neblett Suite 204 2000 Linglestown Road Harrisburg, PA 17110 717.671.8454 Counsel for Plaintiff Plaintiff IN THE CIRCUIT COURT, SEVENTH OF JUDICIAL CIRCUIT AND FOR FLAGER COUNTY, FLORIDA Pamela S. Bottorf v. Richard E. Bottor!. :fr. Defendant NO. 96-752- CA AFFIDAVIT I, Billie Jo J. Kaler, hereby verify that on the 5h day of April, 2006, I did a search of the public records and found the following matters of record: 1. The Final Judgment of Dissolution of Marriage recorded In Official Records Book 0620 Page 0426 dated 06-30-1998 in the Public Records of Flagler County Florida. 2. Notice of Lien recorded In Official Records Book 654 page 1114, dated 5/20/1999, of the Public Records of Flagler County, Florida. 3. Judgment/Certificate of Delinquency recorded In Official Records Book 701 Page 491, In the Public Records of Flagler County, Florida. 4. Order recorded in Official Records Book 1415 Page 1748, of the Public Records of Flagler County, Florida. '\ 5. No other matters of record have been found, nor have any Satisfactions or Releases of the above mentioned documents been made of record. I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. ~ 4904 relating to unsworn falsification to authorities. Date: 1/1L-J J 0 lp c:: ~'-~~ g ~ -otJ:l mn': ~?: tf./~~;. ~#.',~ <::::.CJ -PC'" ~2 ~ ~ - \\ s:" =c"'\". ~ %fA .- ::0\ ;.:., ~ C" ~ ~ ~ cr> ,. . . IN THE CIRCUIT/COUNTY COURT OF THE SEVENTH JUDICIAL CIRCUIT IN AND FOR FLAGLER COUNTY FLORIDA Case: 96000752CA Run: 06 22 2006 Case Type: File Date: Disp Date: (cvprtcpd) Page: 1 PAMELA S. BOTTORF PRO SE Plaintiff Attorney 103.60 C I V I L CAS E PRO G RES S DOC K E T ******************************************************************************** Date Docket Description Number ******************************************************************************** 10 23 1996 10 23 1996 10 23 1996 11 20 1996 11 20 1996 01 08 1997 01 08 1997 01 23 1997 02 03 1997 02 03 1997 02 10 1997 02 10 1997 02 11 1997 O~ 11 1997 02 11 1997 02 21 1997 02 26 1997 02 26 1997 03 06 1997 03 07 1997 04 04 1997 05 06 1997 05 06 1997 05 06 1997 06 30 1997 09 10 1997 03 02 1998 03 13 1998 04 28 1998 05 20 1998 05 20 1998 05 20 1998 05 21 1998 05 22 1998 05 22 1998 06 26 1998 -vs- RICHARD E. BOTTORF, JR. Defendant Attorney DISSOLUTION OF MARRIAGE 10 23 1996 Judge: 49 06 29 1998 Court Cost: Add'l Cost: Claim Amt: Additional Parties NONE PETITION FOR DISSOLUTION OF MARRIAGE FINANCIAL AFFIDAVIT -PAMELA S. BOTTORF SUMMONS ISSUED RICHARD BOTTORF,JR. NOT OF FILING -SUMMONS AND RET OF SERV -RICHARD BOTTORF RET OF SERVICE- SERVD 11-6-96 RICHARD BOTTORF MOT FOR TEMP C/C, Cis, ATTY'S FEES AND COSTS NOTICE OF HEARING 2-11-97 MOT FOR TEMP C/C,C/S,ATTYS FEES NOT OF PROD FR NON-PTY- B & L GLASS 1-31-97 NOT OF TAKING TEL DEPO W/PROD OF DOCS-R.BOTTORF,B & L GLASS SUBP DUCES TECUM FOR DEPO ISS B & L GLASS FAX COPY MOTION FOR DEFAULT-RICHARD BOTTORF DEFAULT -RICHARD E. BOTTORF FAMILY LAW FINANCIAL AFFIDAVIT (SHORT FORM)-PAMELA BOTTORF ORIG MOT FOR DEFAULT-RICHARD BOTTORF NOT OF FILING /CERT OF NON-APPEARANCES NOTICE OF ISSUE AND REQUEST TO DOCKET INCOME DEDUCTION ORDER ORDER ORDER FOR PT CONF, ETC. -PT/ 5-6-97 SUPPORT ENFORCEMENT SHEET UNIFORM SUPPORT PETITION - DOR PRE-TRIAL ORDER -NONJURY TRIAL 7-21-97 SPECIAL APPEARANCE TO CONTEST PERSONAL JURIS JOINT PRETRIAL STIPULATION NOTICE OF HEARING -09-10-97 CONTEST PERS JURIS AMENDED NOT OF HEARING- 11-3-97 CONTEST PERS JURIS CERT COPY ORDER OF COURT - PENNSYLVANIA MOTION FOR CONTEMPT ORDER SETTING TRIAL -5-18-98 MOTION TO TAKE TRIAL TESTIMONY BY TELECOMM EQUIPMENT NOTICE OF HEARING -5-21-98MOT TO TAKE TRIAL TESTIMONY RET OF SERVICE- SERVED 5-13-98 DR. SUSAN MOREY NOTICE OF HEARING 5-21-98 CONTEMPT MOT TO TAKE TRIAL TESTIMONY BY TELEPHONE CROSS NOT OF HEARING-5-21-98 MOT TO TAKE TRIAL TEST PROCEEDINGS 5-21-98 00001 00002 00003 00004 00005 00006 00007 00008 00009 00010 00011 00012 00013 00014 00015 00016 00017 00018 00019 00020 00021 00022 00023 00024 00025 00026 00027 00028 00029 00030 00031 00032 00033 00034 00035 00036 ...... t . . IN THE CIRCUIT/COUNTY COURT OF THE SEVENTH JUDICIAL CIRCUIT IN AND FOR FLAGLER COUNTY FLORIDA (cvprtcpd) Run: 06 22 2006 Page: 2 Case Number: 96000752CA C I V I L CAS E PRO G RES S DOC K E T ******************************************************************************** Date Docket Description Number ******************************************************************************** 06 29 1998 07 13 1998 08 13 1998 10 14 1998 10 15 1998 10 21 1998 10 23 1998 10 23 1998 11 17 1998 05 17 1999 08 25 1999 09 20 1999 09 27 1999 10 15 1999 10 21 1999 10 21 1999 11 04 1999 02 17 2000 02 17 2000 05 01 2000 05 19 2000 06 08 2000 07 13 2000 07 18 2000 01 29 2001 06 06 2005 06 07 2005 06 09 2005 06 20 2005 06 21 2005 07 11 2005 07 13 2005 07 15 2005 07 18 2005 07 18 2005 07 19 2005 07 19 2005 07 22 2005 07 26 2005 08 01 2005 08 03 2005 08 03 2005 08 03 2005 08 08 2005 08 19 2005 08 31 2005 09 01 2005 09 13 2005 09 14 2005 09 14 2005 FINAL JUDGMENT OF DOM OR Book: 0620 OR Page: 0426-0431 SUPPORT ENFORCEMENT SHEET DOR -CASE CLOSURE CORRESPONDENCE FROM -PAMELA BOTTORF, CIC CORRESPONDENCE -PAMELA BOTTORF, CIC ORDER TO SHOW CAUSE -11-9-98 CORRESPONDENCE FROM PAMELA BOTTORF AMENDED ORDER TO SHOW CAUSE - 11-9-98 ORDER NOTICE OF LIEN OR Book: 0654 OR Page: 1114-1116 CORRESPONDENCE FROM PAMELA BOTTORF CORRESPONDENCE FROM PAMELA BOTTORF ORDER TO SHOW CAUSE -10-21-99 CONTEMPT AMENDED ORDER TO SHOW CAUSE - 10-21-99 CONTEMPT COPY TAX RETURN FILED IN OPEN COURT MOTION FOR CONTINUANCE ORDER FOR CONTEMPT CERTIFICATE OF NON-PAYMENT C/C ORDER FOR ARREST NOTICE OF DELINQUENCY CORRESPONDENCE -JACOBSEN AND MILKES (PENNSYLVANIA) COPIES OF CORRESPONDENCE FROM R.BOTTORF CERTIFICATE OF NON-PAYMENT JUDGMENT/CERTIFICATE OF DELINQUENCY OR Book: 0701 OR Page: 0491- CORRESPONDENCE FROM BRENDA BOTTORF POA FOR RICHARD BOTTORF FAX COPY-MOTION FOR WRIT OF NE EXEAT AND FOR CONTEMPT FILE TO JUDGE-KCH - RTND 6/20/05 MOTION FOR WRIT OF NE EXEAT AND FOR CONTEMPT PAY HISTORY PAP#63-A C/C WRIT NE EXEAT AND ORDER FOR ARREST FILE TO JUDGE-SBA/RETURNED 7/15/05 RET OF SRV-SERVED 7/8/05 R.BOTTORF/ORIG ARREST ORDER NOTICE OF HEARING-8-19-05 CONTEMPT/ARREARAGES FILE TO JUDGE-(DEBBIE) FAX EMERGENCY MOT TO VACATE THE WRIT OF NE EXEAT ANSWER OF RESPONDENT TO MOTION FOR WRIT OF NE EXEAT,ETC EMERGENCY MOTION TO VACATE THE WRIT OF NE EXEAT ORDER DENYING MOT TO VACATE WRIT OF NE EXEAT PAP #69A FAX COPY-CORRESPONDENCE FROM BRENDA BOTTORF TO RAE NESCIO FILE TO JUDGE-KCH-RTN'D 8/3/05 ARREARAGE AFFIDAVIT AUDIT ORDER TO RELEASE CORRESPONDENCE FROM RICHARD BOTTORF NOTICE OF APPEARANCE-L.KOLElLAT CO COUNS FOR RESP ORDER NOTICE OF MEDIATION FILE TO JUDGE-KCH/RET'D FILE RETURNED ORDER-ARREARAGE/JUDGMENT AGAINST FORM HUSB 00037 00038 00039 00040 00041 00042 00043 00044 00045 00046 00047 00048 00049 00050 00051 00052 00053 00054 00055 00056 00057 00058 00059 00060 00061 00062 00063 00064 00065 00066 00067 00068 00069 00070 00071 00072 00073 00074 00075 00076 00077 00078 .,- . . ~ . IN THE CIRCUIT/COUNTY COURT OF THE SEVENTH JUDICIAL CIRCUIT IN AND FOR FLAGLER COUNTY FLORIDA (cvprtcpd) Run: 06 22 2006 Page: 3 Case Number: 96000752CA C I V I L CAS E PRO G RES S DOC K E T ******************************************************************************** Date Docket Description Number ******************************************************************************** 09 16 2005 09 22 2005 09 23 2005 09 23 2005 10 10 2005 10 11 2005 10 19 2005 11 16 2005 12 07 2005 12 07 2005 12 07 2005 12 15 2005 12 22 2005 01 17 2006 01 24 2006 01 25 2006 01 27 2006 01 27 2006 01 31 2006 02 06 2006 02 21 2006 03 29 2006 04 03 2006 04 04 2006 OR Book: 1415 OR Page: 1748-9PGS FILE TO CHILD SUPPORT - RTND 9/16/05 NOTICE OF MEDIATION FILE RETURNED TO STORAGE MOTION TO VACATE ORDER FILE PULLED FROM STORAGE NOTICE OF ABSENCE FROM JURISDICTION AMENDED NTC OF MEDIATION FILE RETURNED TO STORAGE FILE PULLED FROM STORAGE NOTICE OF HEARING-01/25/06-MOTION TO WITHDRAW MOTION TO WITHDRAW 3RD AMENDED NTC OF MEDIATION FILE RETURNED TO STORAGE MEDIATION DISPOSITION REPORT FILE TO JUDGE-RAZ - RTND 1/25/06 NOTICE OF CANCELLATION OF HEARING - 1/25/06 @ 10:30AM MOT TO WITHDRAW WITH CONSENT-L KOLEILAT CO-COUNSEL-FROM DEF ORD GRANTING MOT FOR WITHDRAW OF COUNSEL-L KOLEILAT FOR DEF FILE RETURNED TO STORAGE FILE PULLED FROM STORAGE FILE RETURNED TO STORAGE MOTION TO WITHDRAW ORDER-MOT TO WITHDRAW L ROSS FROM PET PAMELA S BOTTORF FILE RETURNED TO STORAGE ** End of Report ** e 00079 00080 00081 00082 00083 00084 00085 00086 00087 00088 00089 00090 00091 g :g;: -ocr,1 ~nj ~~',7l, ~':l-~ (J'..c,. r?C: eli /-(:1 5c ~ . ,. .... ...... ~ ~ G') ~ ~i ~ ~a ~ ~ 0" , I .' '. ..1" "1 ';;1 '"~ '1 ~ ~: ,. ~: . :i; ( I, ~~"'~'l...,t..~'::"~-"oI";'~""."'. .~ ,'_ Inst ND.980l41Sl Det..06/30/l998 SYD CROS8Y, F~AG~ER County 8Y'~"") D,C. nua12::56:;; R~~ 0620PA6E0426 PAMELA S. BOTIORP, PetitiODeI'. and RICHARD B. BOTl'ORF, R.espoIIdllDt. IN nm CIRCUIT COURT, SEVEN1'H JUDICIAL CIRCUIT. IN AND FOR FLAGLBR COUN1Y, FLORIDA . CASE NO.: 96-7S2-CA ... ~ "... "':1 c- , ,~ c:: '" -. ,,", "" - r- !'.... N ", I~(l (.0 " ""1) . ' .. :::a . . . ., f N . -l..... Co) .. n co I ,~ :. ': ii i .' '. '.1- "- .1 "1 ,L~ '~1 ,!ol l~ ;~ :~ ~ .; .. :i; < 1 , ~ ,1,0, . ~~ ~ + ;. b ... ';' '. [ ~~' f ~~ " :.i-~' : :~ J';. .' '0 \, 't.j ',; ,,' ....', I:~ :W ;.;it ";1 -}1 ~ a ,:', :~~ ..j .JI ".' ~":'j 1:.1 ." ," i, ~~~~'~"'-l:..~':;"~-"ol":'~""""" .~ _'_ Inst NDI980141S1 Detel06/30/1998 SYD CROSBY, FLAGLER Count V BVI~-.) D.C, TheI12.56.;! R~~ 0620PAGE0426 IN THE CIRCUIT COURT, SEVENTH ruDICIAL CIRCUIT, IN AND FOR FLAGLER COUNTY, FLORIDA PAMELA S. B01TORP, PetltiClllel', CASE NO.: 96-7S2..cA . ..... ~ ...... ~I "- , S .' .... '" - ,- :- N "I I c.o " I~cn ~ . " , . . . r N .., . -.... c:.:l .. " = '" ,:. IIIcI RICHARD E. B01TORF, Respoadeot. I I1INAL .1lJ])OMENT 01' D'fSSOI.lITlON 01' MARRIAr.R TBJS CAUSE baviDS c:ome on before this Court 1IpOII P .. oCWi1'e aJId Auwr:t thereto 8Dd the StipuIIIion oCthe Putica lIIIIlOunccd 011 the reccml 1995, 8IId the Cowt being fully advised in the premillCS, i ORDERED AND ADJlIDGED as Co 1. I J: '~'" . on oCtile plltieuDd the subject maucr of this action. 2. BOnORP, aacl the HuabaDd, RI bIokcll. , is dissolved becauao it is inelrievably 3. . , A.. ibiIity of the miDorchild, LINDSAY BO'M'ORF, dste of birth November 24. 1990 is awarded to Petitioner. PAMBLA S. BOTTORF subject to fbnher order oCtbis Court. B. The Cowt finds 1bat it is in the best interest oCthe miDor child 1bat the Respondent, :: ~\.~. ".', ': ~~ ': .; '~::;::" ....... :~.,)~; '"JO,:" '.- 7 .~.~. '.'li;" ....;..: ::-: ~':':" .:'r::':~ . ~"'-":': c'\}~ :,.,:..:;: 11.;"/;: . -- :~., , ~ ':. " '.:~ I I ! i , I .' ,~ ..... " ......1 . j ..-~"'-~' ~_.....,_... .....,.-~. '1 ;1 .' ! R~~ 0620PA6E0427 '1. . , RICHARD E. BOTTORF, undergo a psychological evaluation by a psychologist mutually ;', ....., agreeable to tho parties and the Court. Should tho Court appointed psychologist cIccm it nec:esr'Y. 1hc Wife aod the cbilcl will a!Io mcct with the psychologist. 'lbe Wife shall have tho right to 84vi1c IlId ClOJISUlt with the JItIYChologist prior to the time the psydIologist provides any wriltllll rcporlI to the Court and the \IlIlties. The CIItire cosls of the evaluatiOllS sbalI be ":': "'1 ":! ::~! ::~ .:. ,~ .~~ , :;: ,,~ ~. ~.' . ii ..,: RICHARD B. BOTTORF'S sole responsibility. C. There sba11 be DO comm1lllicati.on betweeIl the Husb8Dcl and the minor cbild UJltiI fI1rther order of the Court. Upon COllIplction of the psychological t\oaIuation or evaluations refcmu:cd above. 1hc Court sbal1 bold an OlqICItitcd telephonic bcIriDg to lIIIdnlI& the iJSuc of ,'-.. ~ ):, "'" ~1' $~ .0(' r.... l~: ~: ~ ~~! ~.z., ~!;;! ;;~"l ,~~,j~'j' ..,.-" t~.J ~ 11 . ;l~ ~:/~: '~':. }:~: }~.". ~ ~~~~; :~t~. ..:~.~. If,~:. -.1_1 ., .:~'..;: l :. "~', '. '.~.j~,;:i ';~' , - .' telephonic COIIIIJl1IIIication bctweeu tho Husbllllll8Dd the a written stipulatiosl prior to that elate. D. Both parties rccognize and agRIl that each parcIIt baa a . 'leI, IIIIlesa the panies eater into .,-', BotTORF, sball pay 1hc S1IID of four hundrccl twenly-sill do forty-eight centa (5426.48) along with 1hc statutory fee, on the lUst of each lIIId eYGIY gh the C1esk of the Courts, Post OfIiee Box 787, B1IIIDCU, Florida 32110. In urt eatablishca anean in the aum of$8,953.78, I~esenting the R tspOlld~t's child support obllption fiom the date of filing of the petition in life; that the minor chilcIlhould not be questioned about that fiom being plCIeDI during the par=ts' :;,; ,.,. being IIIecl by eithQo paRIIt II a spy, a co . that neither pareDt sbal1 ". . './':. .. . t.:.... . cIiapange the othet in 1M plIl8CIICC 0 " 1'.:.,.,. I' . .' l,., . .,'. .' ' ': , '.' :.:;:: ,.'" the iII8lIDt case. Said Sl1C8I'lI are due instanter. The inCOIDC cleduction order entered on Febraazy , I : ..,..;. ~... ~ :.: ! ~".'" , ~.:,:":. 26, 1m sbalIl'OIllaiII in full cft'ect until f\Jrtber ordcr of this Court. .i_.._ _' f.' - I i ; . , I .. '. ".., I --~'/"'.- ..........-'...._....,......." 'I . , a~t 0620PA6E0428 indirectly, whethar in penon, by telephone, in writing, or by computer. Aut relief ll\'IDlec1 by this iqjUJlCtion abaIl be offective until f\u1hor Court OIdCll'. Pursuant to Soction 901.15 (6) and (7), III oflicormay anat Respondent without a warrant for violating this injUllCtioa wbon !bo officor bu pI'Clb.ble causo to beHevo Respcmdont bu (I) kDowingly committed and act in violation of'this injunction wbichctelleS a threat of'i1mIlineBt ~ , "; ! I I I . . .-.-" . ..!t','. ':::,:::" ",:::,'1 ~~!{\ ~:.~:. .'~~~ ;i~~ ?~!. ~~. ;",." :~~.;; ~"\~:' :~;..' ~~;, 'iir~r:. r.<<~'" :;}1,'; ~"-.:. ~:::" ~71~1 ~..~ ,:!,rt.j ..~,. ,~,.J ~,,!...' :i;B; ~7. !r..~' .,.1.~ ~.".., ~:~ .!~:: .i.i;'; :;'~ :~~ ::.~1:i ~~l;'\:~:-! ,,'.., \~:Y~j ...~.,. ,\ '~~fr7.~ f~~~ :X! '::',1 :' ~':1.: .~ ._~... ~', . ~5J ,I'" ,,;~j.: .,-" ....,. ,':" d8llger to tile Petitioner or ho1Iaeholcl JIIe1l1ben, OVorthll objoctioD ofPcliticmer. if llllC unry; OR (2) eommilted an act of' cIoD'eotio violeoc:e u doJiDocI in section 741.28, Florida StatUtos, and the officer reNO".hly beliOVllll that thoro i. dlllIp of violenoo unIoas tho person aIIopd to have OOIIIIIIitlec1 tbe domestic violeDco is arrested without delay. Thia parasnph does DOl limit or February 26,1997. tho Court ''', oxpand !bo officer'. artllIIt aatbority COlIfoned by any other 910.1S, F10rIda Statutes, gllllalllly.) 1\espondent sbaI1 '0Il of law. (See SeotiosI ".' ImIled for a crime and thereafter may be 8dmillec1 to bail in tho provisi- of cbaptcr 903, Florida StItUleI and tile appIicabl prococIure penlfi"S haring or trial. . ,~ s. ATI'ORNEY'A I'R1PS: . fees in the IUID of$750.oo and orden ,,':;i 6.. : The Coun specifically 'IllIIeIVCS I...:' I".' I. . I'> ,. . :, ;.l~' , .. , ; ,< !",:. I.... ( .,' Leonard R. Roll. Bsq . RSCIVllII ruling with 's feos on behalfofthe Wife. jurisdiction u to the disaolulioD of marriage graalec1 in thia juclpllOJl!, the issuoa of child custody, viaitation IIIICi suppon and tile enforclllDent thereof. The Court will reaorvlllisla1 ruIin& with n=apect tho isauoa pertaining to oustody, visitation, supJlOlt, attomoy's f_ and cosIS. The Court ^. ; I .. ~ -",. - ." ,. a~~ 0620Pl6E0429 F. The Wife has IIogteed to tenninate her action iu CUlllberland Collllty, PlllIII&Ylvaui.a ,.' ....,. ,--, "';., with respect to cbild support 8IId aU child IIIIJlIlOIt obligatiODll of the HIII\land, RICHARD E. BOTIOJUl,Ib811 be paid through the Clerk of the Court, FJasler County. G. The parties sball elIeh be obligated for fifty (50%) of aU medical bibs DOt covered by iDsuraIIce OD behalf of the IlIiPor cbiJcl. The CIIITllIIt medical axpellSClI_ established at eight hUDdrec1 seveuty.two doU.. 8IId fifty-sevCII CCIIIS ($872.57). RICHARD B. BOTrOltP sha1l pay to P AMBLA BOn'ORF the 1111I1 of four \n1ndrecI tbirty-six dolbas anc1 twCDly-cigbt CCIIlI (5436.28). H. RICHARD E. BO'lTORF sbal1 maintain his present life iDsurance policy with a IIIiuiImw1. vahJeof$IOO,QOO.OO. MlDingthe miuorchi1d as the miuor child reaches the age oflll8,jority. to 4. ~r.nnN: 'l'bc ilIjllnCtion dated August 30. 1 when:by R~usbuld, RICHARD YioIeDce. abQSCl, threat, or ~ at stPIkiJls. or my c:rimiaI1 ofl'eale .;' .~ '.' :':~:'. : .-' ..~.'.~ '..,,::.~,' .~~;;' 1...; ':;"1S ~~,." !!,-.~ ~., :.?-::; 1;l@:. .!"~T...... ~,,:;. ~;" 1 ~l;:; ~,., I~i ~'i~> ~~~~i:/'" . ~\.. . I~ ':~7~~>'j t}r' ~~~~f':':: ;. ~.;.. . ;. ;:.M_, . ~::':;:"'.:.. " resulting iu pbyacal injury or PetilioDel'a ~""Illte er onIe:ed DOt to cause my other pcnoo to COIIIIIIit IIIIY lICtofvlo RespoadenrIBUIbaDd residential preaUlICII ofPelitionerlWUc, BvinS JIm Coast, Florida or wbemer Pelitiollel'l\Vd'e may Bve iu the State oCF1oricIa. ~usb8IId sha1lllOt go onto PelilionerlWife'a place of ".,.;. ..... ...... .,. " !;i{::::i ""'-" .~~..:" employu1CIIt or wh_er Pelitioncr IlI8Y be employed or attend adIool ill dae State of Florida. RespoadelltlflUlbaDd shaJ1 J10t COlItact the PetitioncrlW'U'c or the minor child, directly or ..<~' ."', " .',. ..- ! ...,._....-....._,....,..~' -.,.'''. . ~~& 0620PA6E0430 indirectly, whether in person. by telephone, in writing, or by computer. ....,;" ~ ' ,'.'. As1y relief graated by this injunction sball be efrectivo until fbrther Court Older. PursualIt to Section 901.1S (6) IIJId (7), an officer may arrest RespondeDt without a warrant for violating this injlllldiOD when the oflicer bas probable causo to believe ResponcIent bu (1) ,,' ,." . ;~( ~...'" \;::~~ iJo'-:. ~r~~.. ",.,., ;)},~l :;;;\..~ ~~:'" ..i.;.'/" :lt~': tr.:~.. -,,-'''.' 'r~~'.,' ~rir.~' ~1c" ',r",,' ~{f., I!i~.' :q:1-1;'~'i t~~.l i~f:""~'l ~i danger to the PetitiOller or household mfllllben, over the objection ofPetitiOller, ifllllC 11I11)'; OR I knowingly committed IIlId act in violation of this injllllCtion which aeates a thrc:at ofimminCllt (2) collllDitted IIiflItt ofdlltbClltic violence as de1iJled in SIlCtioIl 74'1.28, Florida Statutes, 8Dd the ofiic:er reasonably believes tballbere ia danger of violence unless the penon alleged to bavc committed the ~cstic violence is urested withellt delay. This paragraph does not limit or expand the oflicda arrest authority conferred by IIlIY other tho Respondent, lU LconardltRoas, reserves ruIins with I i' I. i: il j' 910.1S, F1oridaStatIItea, generally.) Respondent chapter 903, Florida Statutes and the app6 trial. wilb the proviaIona of pzoc:edare p-lil1l! hearing or :~:~.::.. 'fl.,;' ,~: :~~:~~r~ ~~JL i'~i?': ':,'0'.:.'. "'';'' ..' ::::.... febnwy26,I997,lbeCourtaw . fees in the awn 0(5750.00 IIIld 0Idcrs said IIIDO\IIIt instanter to the Wife'. counsel, I I .' i , , , Avenue, Daytona Beach, Florida 32118. The Court 6.. : The Court specifically reserves ;' r ! i i i I , I I I I I I attorney's fees on behalf oflbe Wife, ::1.:..:.... '~'"J.. .; :' ~": ," . :_,1:'-.. ".;'~' . . . jllriadiction as to the cIisaolutiOD ofmarriage granted in thia J""r"lIIt, the iasues of child custOdy, visi1ation lIIId 81Ippott IIJId lbe llDfoJcemant thereof. The Court will reserve final ruIins with ;':'. ~~. ~, " . respec;t the iasues pertaining to CIIStody, visitation, support, attorneY's fees and costs, The Colllt . " '.i. '~.' . ..' r~" . .;;j::~~~~-?1~~"'.''''.~~,~~:':'f~'~'!:'':-'::!':''i'':'i."..~~".,,,.. ....._ !t .. ~~: i.,;' '':~~: .,.., . -.. .. .~. .,1. '~., ~~. ;;;;1 ~~ ~.tl l'\.:1 Y.l'''''i. ,.,!:) ..... ::>;:t'l' . ~ ~ ~.;. iii(.'j ilr.~1 ,,", ~J: ~... "'II:. ~~ ;.;.~.~ ~; ~:, ~; ~' ~:, ~! ~..11 ~I ~.-;. ..." 2~~ 0620PA6E0431 order orFebruary 26, 1997 sbal1 remain in 1WI force 8IId effect. Furtber. bolh parties II'lil ordered to tako whalevcr lCtion nee-~ to, IIId CODduct thGmse1ves in Uly lIIJI\ner conducive with, carrying out the inteol Uld JlUl'POIO orthis JudgD1eDl. DONE AND ORDERED in ChImbers, at BUIIIIe\1, Flagler County, Florida this ~ day or ~t998. cc: LeoDIni It. Roll, Esquire David Fuller, EaquiJe ~Ir'i ~ J1-1 .,. ~1. ifu~ i~! 1....; ~.-'i-. " "l" ~:,.. .,.~:.. ~ '" ~.. ~~: }~~ :':"'~l:o '\:,.- 1\;:',:, ""'" ..",'t. ~'; Vi"j; ~~ /l';'~ ~~~ ~:.t'l {'~j:~! :':;:":;i ;."tt'.:: ~l''';1 ~:.{~ ......,., ';""'1 ~~:.~ '. ~~\I ....; I::~ ~. ~::'., '", .!~(:~ .:fr. .. . 1.': " ..:: i; I'" : :..~ I.... f:< . .~ "". .'" :'i.~ :;~:; "', i~::: ) ',:,y "i! '.::~ ;~' .'.t ~~ ~..' .::' '.,. i;~ . /~~ ",.) :.:~ ~~~P: 'l;'l '.-..' ''':j ~ Ifii ".,' .t:~,:~ I~;l'i (,;~ 'I~"~ ~:t :,J. .'.' ':' ::.; }. ;. /.: " ... .. -......... : .~~,..r",,!~~~-:-.:-__....____ . .~.._.......~__r",,',~""''''''''''r.I~:~,-~..,...:l,-......1~ <;.........~~~,.,~.~.~:-.r..'..~..""...r.~":O'I'_...........j';..."-':,...... l./r' I I I , ~1 ":" f~'! ;.~:li ~~::' ,.,\ ", ,~ ~,J ':'.,1 ,.,:.. ,; ~.,"~ ..." :'~.i .:.~.~ "1";' 1;:, l1 ,,':': 'f... "i-', l....'f TO: Flagler County Clerk CoUIIty Courthouse P.O. Box 787 B\IIl1lC\1, FL 32110 OMB CcmlJo~0970-0153 Ot;.,~,+~ ~:-o,..~ Obligor: Ricbard B Bottorf lr "", ~"tt;~~ 40SWrenCt 4, ~ J;>'~ Meehmicsb1q,PA 1~~" .1-;:'" i . OOB: 1211111959 , .~ l SSN: 168-48-3931 "" :! n~~~~ ~ . ~: :~:'65 Obligee: PemeIa Boj \ ~ ~ ~ I Phone: (512) 437-6023 19 Putter Dr iii: .. .,11II -.. 511II- !" Fax 1#: (512)437-6031 SYD taIf, FlJaD CIIIl1Y StateBari#09307050 PalmCout,FL32164 BY. ~.~,. "'c. 31M C'loitlUlut's Cue I#: 96-752-CA 11II: "fb.~6M .. fflf'. Tbillicm JeSUllS from a child support order. cntmld on 0612911998 by the CiJ.m ~ ;; , " 0 Flagler CoulIty FL docket II\IIDber 96-7S2-CA. TbiI onfer requiIes the ~~ed obligor to pay cbi1d. support in the IIDOIIDt of $426.48 per moDIh, NOTICE OF LIEN ~ I': ., J ~ \'1 "', :" '-f~ i1: 1:4' ,r "', .' '. ~ i: } ~' '" ~ ~ .." . As or01J1811999.1he obligor owes unpalcI support in the IIIICll1IIt of$l2,l23.88111d this lien lIIIlO1IIlt may be subject to interest. " Prospedive 8II1O\IIIlS of child suppon. ~t paid when due, lie j IIIIOIIIIt. TbilIIea lUaches to IllllOlHlCtlllpt real and obligor. which is loe11ed or IOIlOfIIecl witbiD the .-J. filiDa, inclucIIDg III)' JIIupelly speciflcll1y clescribed be Specific clescriptlOl1 or property: AllIlOl1-cxempt real Uld perlIOII8l not limited to, the following: wages or other compellllti cIIlms for cIamIsa or cboIes-in-actIon, stocks, boads or other or liCIIII 011 Uly real or persoIIIl property, promissory DOta, drifts, b' or other c:ommerciIl pIper,judgmllllls, or other llIIt-issued bcmcIs or securities, III)' interests in oil, Cimificalel or cIeposit, 1elIers or ctedit, money otders, cuhi ',checks, bllIIk clcposits, or escrow fimds, trusts or trust indivlduI1 reti!ement aeoountI, protiWhariDs pl_ cl , peaaion pl-. pre-pald t\nIcnl pl-. retinlmeDt beD 1-. life estateI, _.i....... interests or other . in fell property, patents, trademarks, copyrights, service marks, . ses or other licenses. Uld IICCrIIC to the lien or1he above-lIIIIIelI . or1he state or NaIl.. of Lilli ......'of3 I" I' t I I \,' ': r 1 j , " j ~ . ! ! " .,." ..., :',~ " :; ;~.;. ~..... :.:.,: .."~ " q. q' I I ...-.-. . .-~"""""""'~""'--- -- . . , l.,., ':..,~ ,;';1 ::/,\ ," ...,": }!~l "', !~~l' j"'';':, '04 "", ~' " .,..:l :;:"~ .~..,1~ {~~ ~,,;: \':~"l ~~} '~;i' .'t..: .'#:.' .-. ~ :. '. .. ,( '" , I~ C .. ' ~ '. ~ j;' . 'I!,' ., t'i.i k ..z. .... ':~ .;~; i I: The priority IIId enfon:emem upec:ts orthis Jillllll't goveraed by the law orthe state whete the property Is loc:ated. An obligor mllSt foUow1he 1_1IId ~ of the ... where the property !l1oc:atecI or reoordccl to COIltl:St or ~hl1qe this lien. TbIs lilll !llIIIIiDS in eft'ect UlIlil released by the cIaimInt or in IllCOrdaDce with the laws orthe stale of fiIIas. JII: IIlUlltllll IIIIlEJ 5I!II1. Iff lEt. ~ Ut5 N01II to LieD Recorder: P1eae provide the .,1';"'_ with a copy of the filcc1lieo, COIIlainins the reoording informatlOll, at the lIIIcI.- provided above. Check either "A" or "B": A OIasued by a lV-D ageucy/ofliee As Ullllltborizecl agent of a illite, or IUbdivlsion or a stale, reaponII'ble tor impJ........mI"g the c:hild IIIpJlOrt eafcm:emeat prognm set forth in ntle lV, Part D, oftbe FedecIl SocIal Se=ity Act (42 U.S.c. 651 at seq.). I have authority to file this c:hild IUpplIrt Ilea in III)' state, or U.S. Territory. For additIoaal information teprdlq this lieD, . tbe pay-off -.at, p~ contlICt the authorized BgIlIlC)I (c1aimUlt) . the lIIIcI.- provl PI.- ..("'_ the _ II\Imber. also pro'Iicled above. Date A1Ilhorizecl Asent B [.I] Iuucd by a private (IIOII-IV-D) Ittomey n I am Ullttomey repJelCllting the above-aamccl Obl~ . acoordance with the laws ortbe stale orFL. For lIddlt:I iDcIudiDg the pay-ottamoUDt, pl_ above. Il111l1111'Y 18,1999 this lien is Issued in 'on ~ this Ueo, ) at the addtesa provlclccl \ or Obligee ............. _ III lion OMS Concral" _"3 .....2013 ... ....."<;;,,,--~ . -' 0, 1 . " ' , ! ',,' .,,; " ~ ,.," .. ~ ..... , ..... ,"', " ':': r: i, f'.'. r:' I, r I", I i I , ._-..~ _ J \oro. lnat No: 2006017295; 04/04/06 11:09AM; Book: 1415 Page: 1748; Total Pgs: 9 GAIL WADSWORTH, FLAGLER Co, AUft 10 05 04:3Gp P-"s&Burd.n 3862580030 p.3 IN RE: The Marriage of PAMELA S. BOTTORF, n/kJa, PAMELA DENT, Petitioner, IN THE CIRCUIT COURT, SEVENTH JUDICIAL CIRCUIT, IN AND FOR FLAGLER COUNTY, FLORIDA CASE NO.: 96-752-CA and "'t: : ~ ~ J>-< '" ,.., '" z ? ""'-1 ("').." ~.- r- r= :t> t., P1 :~ ,::1 r-, r- ::~ ., '.:r~ ~_;;~., z ORDER ~ "":) :3 .,.. r c.. ':'? ,...: ~ RICHARD E. BOTTORF, JR., Respondent. ,-, ' : p', . ','7.., ",. ~: I ''- ~ THIS CAUSE having come before the Court upon the issues of credits and arrearages pursuant to the Court's Order dated August 3, 200S, Uld the Court being otherwise fttlly advised in the premises, it is hereby ORDERED AND ADJUDGED that the Fonner Husband's current arrearage figure for child support is $32,229.39 and his arrearage for previously-ordered costs is $2,144,07 for a total of ~ usband in the amount of amount of$34,313.46, A judgment is entered against the Fo $34,373.46 for which let execution issne, DONE AND ORDERED in Cbambers at Bunne .200S. cc: Leonard R. Ross, Esquire Lauren Koleilat. Esquire Bo,pk: 1415 Page: 1749 Aue 30 05 04:37p ~-"s"Burden 3B62580030 p.4 :;:Oif~.s>e:r~.G-~~S .... <IZ~~ .... (")tI:l I,/) l: 0 .a ~ ~~ ~;lg:-i'< '<Et~cr \0 .. ~ t i ~ = or II l i r r ~~ "'II 9~ ;,oe e~t~~~t~~~tt ...."...ca..~ ~~ - I->~I->I-> _. 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'"' ;.. ... b: \0 1M '" 00 .t-' .... t !:l ~ 1M i "'g-g 08i 'g ~ ~, ::I 'l:j I .... '" ... ... ~ ('l ~ Book: 1415 Page: 1753 Rue 30 05 04:3Sp P"ss"Burd..n 3852580030 p.e " '..--- IN THE CIRCUIT COURT, SEVENTH JUDICIAL CIRCUIT, IN AND FOR FLAGLER COUNTY. 'FLORIDA CASE NO 96-7S2..cA PAMELA S, BOTTORF, Petitioner, v, RICHARD E. BOTrORF. JR" Respondent, I ORDER FOR ARREST TO ALL AND SINGULAR THE SHERIFFS OF THE STATE OF FLORIDA GREETINGS TInS Is to command you, as you have heretorore been commanded, to take RICHARD E, BOTrORF, JR., if he is found in your County, and deliver hiIn for transpottatioD to the Flagler County Jail where he is to be incarcerated for a period of 90 days, as a IXlIISCqUeIICe of his contempt in failing to comply with the previous Order of this Court entered herein on November 3, 1999, a copy of which is attached hereto. DONE AND ORDERED in chambers County. Florida this. 16" day of February. may be released from custody Support Division, the sum of I al8 pay $25.00, Sheriff's Y the Flagler County esulto"f this order, The Respomieni may purge hiInself of the said con by payment to the Clerk of the Court of Flagler County, $2,000.00 together with $5.25. Clerk's cost, and pri costs. The Respondent shall funher pay prior to reI , any costs Sheriff or any County Sheriff's office for transportation or otherwise u house, Bunnell. Flagler cc: Richard E, Bottorf, Ir" 405 W Pamela Bottorf, 19 Putter Drive adak: 1415 Page: 1754 Aue 30 05 04:38p P'>55&Burden 38S2580030 ...."':' / / . / ,. // i " PAMELAS. BOTTORF. Petilioner, and RICHARD E. BOTTORF, JR., Respondent ,., 1,; iIlli C.LR,i,.;JI1 (;()UKi', Sr.v.bNHi JUDICIAL CIRCUIT, IN' AND FOR. FLAGLEll COUNTY, FLORIDA CASE NO.: 96-752-CA I ORDER FOR CONTEMPT THIS CAUSE came before the Court a motion for contempt filed by the Petitioner and motion for continuanco filed by the R.espondent.. The Petitioner was present for the hearing; the Respondent was absent, however. he wu .~.onted.by Jerome Rotenberg, Esq. The Court having reviewed the motions and heard uguments and evidence of the parties. finds that the Respondent has not paid the court ordered clilld support Additionally, this Court finds that the Respondem po--.s the ability to pay the amount imposed by the Court, however, he has' dimgarded this Court's order, THEREFORE, it is hereby ORDERED and ADJUDGED that 1, The motion for continuance is DENIED, 2. Respondent, lUCHARD E. BOTTORF to pay child support. He is in arrears ' 21, 1999, 3, Respondent is to selVe.iJ2. da U1 . er Co ty Inmate Facility; such sentence is suspended providing the sea himself by paying $2,000,00 within 20 days oflhis order to the of Court, Poat Office BolC 787. Bwmell, FL 321 10. S . inclu e Cleric's fee of4% or a flat fee of $5.25 which ever ess, Th Respondent sbaJI pay a total or $2,005,25. , in contempt . s Court's order nlof SI7,483.38 as of October 4. The purge payment shall Ii cashiers or certi1i It. collected by the unty SIi de. pursuan this Order, by cash, money order, d in the process or purging may be on behalr of the Clerk of the Cin:uit Court. p.9 Book: 1415 Page: 1755 3882580030 p.l0 I AUI 3D 05 04.38", , ., ., . l' -'-1" i , , i , I ! JI.,...aurde" \....; v \o.~+ t':t.~1 in I""!,...lt ....r..... ~. ~ ..-.. . ..,....:..':d ".. ...1.,\ '""~'IJ.........,.:" n ,1;!; lJ ":"".:. :, ~~'.,. "I'''~':'I .". ~.~.., .,\..... 100-_:...." ." -............1..1... ..... ~....'- .~".......~..Vl, 4.I'."olIt....k", ~ two days' ofneeipt. S. AjI). "t, ia~...... tile 'tIPOIr'MJt in tIII--.mt or$17.483,38 fbr wbIch let -.tiOIl eater. .' DONB aod O~,' ' ,,' ~ ...l'IItIIr euu.r, .CounIIouIe, inBunnelJ, PII8Ier County, F1ori..tIU~dlyafNovembel,l999. ~ /}/ _ C '/Da<:'~ caa1I1' J'tJDGB cc: PlUlIeI& Bottorf 19 PuttetDrive Palm CQUt, FL 3~164 Richlrd B. Bouar( Ir, 4(l5 Wren Caurt Mecbuicabur&PA 17055 ! L I I Book: 1415 paqe: 1756 Rue 30 05 04:39p o"!ls&Burden 3882580030 Social Security Administration Retirement, Survivors and Disability Insurance .....- " r I 1 "'Ot,l~u VA ...'...\i"'...\.i.'\..i Offioo of CenCa'&1 O~tions 1500 Woodlawn Drive Baltimore, Mar,land 21241-1500 Date: October 9, ZOOO Claim Num~r: 168-48.393tHCl PAMELA S BOTl'ORF FOR LINDSAY MAE BO'l7ORF 19 PUTTER OR PALM COAST, FL 32164-7.(04 1"11,..1.1,,.11.11...1..11...1,1..11I....1..1...11101..1,1,,1 LINDSAY M BOTTORF is entitled to mOlltbly child's benefits beginning March 1999, We ha"" chOllen you to be bu ",presentative payee, Therefo",. you will receive her checks lUld use the money for her needs. What We Will Pay ADd When . You \vUl receive $4,172,25 around October 15, 2000. . This is the money LINDSAY ill due for March 1999 through September 2000. ' . LINDSAY M BOTl'ORF's next; payment of '291.00, which is for October 2000, will be receiY8d on 01' about the third. Wedneeday of November 2000, . After that you Willl'eCslve $291.00 00 or about Wednesday of each montli. . These and any future payments will go to n you selected. PIe8.. let us, know if you cllange . 10 we can send you letters directly. . Later in this letter, we will show you h red the... amounts, The day we make payments on this rec:ord ' JR's date of birth, Enclosure{s): Pub 05-10076 Pub 05-10077 Pub 05-10076 c p.ll d,. I 3 (") '"'" ~ = c = = ;;.? ~~ -0ijj """ n-:r;' c:: .;:: ~'.~' , (;" (',i) :ny s:- o ..:..< ~. --1~r~ r:;,:C) -u :x: -d ('I :x t:;~ c' (~: - --I -./ .. ~ .::2 w -' ,. PAMELA S. DENT f/k/aPAMELA S. BOTTORF, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLV ANIA VS. RICHARD E. BOTTORF, Defendant NO. 06 - 4658 PETITION TO STRIKE FOREIGN JUDGMENT Identification of the Parties: 1. The Plaintiff Pamela S. Dent f/k/a Pamela S. Bottorf is an adult individual with an address of P.O. Box 740208, Orange City, FL 32774. 2. The Defendant Richard E. Bottorf is an adult individual with an address of 810 Sherwood Road, New Cumberland, Cumberland County, Pennsylvania 17070. 3. The parties are the natural parents of Lindsay Bottorf (DOB 11/24/90; Age 15 ~). Summary of Petition: 4. This $34,373.46 judgment stems from Plaintiffs child support action in Florida filed January 7, 1997 for the period September 1, 1996 through June 30, 2001. However, the Plaintiff first commenced a child support action against the Defendant in 1992 and 1993 in the Domestic Relations Section of Cumberland County while she was a resident of Pennsylvania. The Pennsylvania child support action was not discontinued until June 5, 1998. In April 1997 the Defendant suffered a broken neck requiring cervical spine surgery and extensive physical therapy. Our former President Judge George E. Hoffer issued a series of Orders holding that the Defendant was incapable of work effective May 15, 1997 and this continued until he was granted Social Security Disability in September 2000. The Pennsylvania child support action filed by the Plaintiff as a resident of the Commonwealth of Pennsylvania was never discontinued until June 5, 1998 at Plaintiffs request. The Plaintiff never complied with the Uniform Interstate Family Support Act (hereinafter UIFSA), 23 Pa. C.S. ~7205, because the Defendant did not consent to Florida jurisdiction over the child support case. Florida could only assert jurisdiction over the Defendant in the child support claim if the Defendant - as required by ~7205 (a)(2) ofUIFSA - ''filed a written consent with the tribunal of this State for a tribunal of another state to modify the order and assume continuing, exclusive jurisdiction. "Defendant's due process rights were violated by Florida improperly exercising jurisdiction over a child support claim when UIFSA required Pennsylvania to retain continuing and exclusive jurisdiction. Therefore, the Florida judgment is improper and must be stricken. Factual Background: 5. On August 14,2006 the Plaintiff filed a Praecipe to Enter Judgment in the amount of $34,373.46 as of September 13,2005 against the Defendant pursuant to the Uniform Enforcement of Foreign Judgments Act, 42 Pa. C.S.A. ~4306. 6. This judgment is based upon a child support arrears allegedly owed by the Defendant commencing September 1, 1996 through June 30, 2001 issued by a county court in the State of Florida. 7. The Plaintiff, however, had previously initiated a child support action against the Defendant in Cumberland County, Pennsylvania docketed to Case Number 595 S of 1992 on June 18, 1992 as shown on Exhibit "A" (Complaint for Support). 2 8. Plaintiffwas a resident of Pennsylvania living at 655 Lewisberry Road, New Cumberland, Pennsylvania 17070 when she filed the action in 1992. 9. The Plaintiff then filed a second complaint against the Defendant in Cumberland County, Pennsylvania docketed to Case Number 595 S of 1992 on August 3, 1993 as shown on Exhibit "B" (Complaint for Support). 1 O. Plaintiff then resided at 10 Marshall Drive, Camp Hill, Pennsylvania 17011 when she filed the action in 1993. 11. In September 1996 - at the time the alleged child support arrears commenced in the Florida case - the child support case against the Defendant filed by the Plaintiff had not been discontinued in the Commonwealth of Pennsylvania. 12. On August 11, 1997 the Honorable George E. Hoffer issued an Order regarding the Defendant in another Cumberland County case holding that: IT IS HEREBY ORDERED AND DIRECTED that the support order be suspended effective May 15, 1997, due to cervical spine surgery. Defendant [Bottori] was unable to work and has no income from any other source. (See Exhibit "C"). 13. Two years later on August 19, 1999 the Honorable George E. Hoffer conducted an evidentiary hearing and determined that the Defendant continued to have "no ability to perform gainful employment". See Exhibit "0". 14. This finding was based upon repeated certifications by Defendant's treating physician that the Defendant was "continuously disabled and unable to work from 4/97." See Physician's Information Request Form attached as Exhibit "E". 3 15. This August 19, 1999 Order was issued in a Cumberland County child support case captioned as Tracey J. Gordon v. Richard E. Bottorf, Jr. in DR 11,846, No. 641 Support 1984 and stated: AND NOW, this 19th day of August, 1999, testimony having been taken as to the Defendant's ability or inability to work because of a medical condition, we do find that past medical condition continues and that at the present time he has no ability to perform gainful employment. Should the Defendant be successful in his request for social security disability income, he is directed to immediately notify the Domestic Relations Office of that situation. [Emphasis added]. 16. It is res judicata that the Defendant was unable to perform any gainful employment and had no income commencing May 15, 1997. 17. It is also undisputed that the Defendant began to receive Social Security Disability in September 2000. 18. Despite a pending Pennsylvania child support case initiated by the Plaintiff against the Defendant in 1992 and 1993, Plaintiff filed a "Motion for Temporary Child Custody, Child Support and Attorney's Fees and Costs" on or about January 7, 1997 docketed to 96-752-CA in the Circuit Court, 9th Judicial District, Flagler County, Florida as shown on Exhibit "F". 19. Plaintiff then obtained a child support order from Flagler County, Florida on February 26, 1997. 20. It is believed and averred that Plaintiff did not inform Flagler County, Florida of the pre-existing Pennsylvania complaint for child support filed by the Plaintiff when she was a resident of the Commonwealth of Pennsylvania. 21. Plaintiff then requested that the Florida order be enforced under the Uniform Interstate Family Support Act (UIFSA), enacted in Pennsylvania at 23 Pa. C.S. 971 0 1 et. seq. 4 22. Plaintiff did not file any discontinuance of the pending 1992 Pennsylvania child support case docketed to Case Number 595 S of 1992 before proceeding with the Florida action in 1997. 23. On June 5, 1998 the Honorable George E. Hoffer issued an Order in the Plaintiffs case against the Defendant (592 S 92 - Cumberland County) which states: AND NOW, to wit on this 5th day of June 1998, it is hereby ORDERED that the support order in this case be terminated without prejudice, effective May 13, 1998 due to the Plaintiffs [sic] request to stop services through Florida and Pennsylvania. Arrearage set at $8,279.67, Defendant is to pay the costs in this matter in the amount of $21.50 by July 1, 1998, See Exhibit "0", 24. It is believed that the Plaintiff knew at the time she directed Cumberland County Domestic Relations in late May/early June 1998 to discontinue the action that no Pennsylvania court would collect child support from the Defendant in light of his inability to work due to cervical spine surgery. 25. It is believed that the Plaintiff intended to secretly pursue the action in Florida despite the fact that under the "Continuing, Exclusive Jurisdiction" provision of 23 Pa. C.S. g7205 (Uniform Interstate Family Support Act hereinafter "UIFSA") Pennsylvania remained the sole, continuing and exclusive jurisdiction for all child support matters because: (a) Plaintiff had commenced two child support actions against the Defendant in 1992 and 1993 while a resident of the Commonwealth; and (b) the Defendant never filed any "written consent with the tribunal of this State for a tribunal of another state to modify the order and assume continuing, exclusive jurisdiction" which is required under 23 Pa. C.S. g7205 (a)(2). 26. Plaintiff - despite knowing of Defendant's total disability - continued to pursue the Florida child support case from September 1, 1996 through June 5, 1998 while she had an active Pennsylvania child support case open against the Defendant. 5 27. Plaintiff - despite discontinuing the Pennsylvania child support case with the representation that she had also terminated the Florida child support case - secretly kept the Florida case active after the June 5, 1998 Order by former President Judge Hoffer thereby accruing tens of thousands of dollars in claimed unpaid child support for a period of time in which the Defendant was completely unable to work and had no Income. 28. For the reasons which appear later in this Petition, the principles of res judicata preclude the Plaintiff from submitting her child support claim to Pennsylvania jurisdiction in 1992 and 1993 but then attempting an "end run" to Florida when a Pennsylvania court determined that the Defendant had ((no ability to perform gainful employment" as a direct result of a medical condition. 29. The Defendant was no longer able to work starting in April 1997 due to complications arising from post cervical spine surgery and this disability has continued to the present. 30. The Defendant was never a resident of the State of Florida. 31. The child of the parties was not conceived or born in the State of Florida. 32. The Plaintiff moved to Florida with the child in April 1996. Petition to Strike Should Be Granted Since Florida Judgment Violates Defendant's Due Process in that a Court of Competent Jurisdiction Determined After a Hearing that Defendant was Incapable of Work Effective May 15, 1997 33. The provisions of the Pennsylvania Uniform Enforcement of Foreign Judgments Act, 42 Pa. C.S.A. g4306 "have been interpreted to mean that any foreign judgment properly filed in Pennsylvania must be accorded full faith and credit unless there is a particularly overriding reason that requires [the court] to deny full faith and credit to the judgment. Only defenses which destroy the full faith and credit obligation, such 6 as a lack of due process or opportunity to defend, or absence of jurisdiction may form the basis for [a Court to deny] enforcement of the foreign judgment." First Fidelity Bank, N.A. v. Standard Machine & Equipment Co., 398 Pa. Super. 607, 581 A.2d 629 at 631 (1990) and Joshi v. Nair, 418 Pa. Super. 448, 614 A.2d 722 at 732 (1992). 34. Only those defenses such as a lack of subject matter jurisdiction, a lack of jurisdiction over the parties, a violation of [a party's] due process rights, or a lack of meaningful opportunity to appear and defend, can be considered as a basis for denying a foreign judgment full faith and credit. See Greate Bay Hotel & Casino, Inc. v. Saltzman, 415 Pa. Super. 408 at 413,609 A.2d 817 at 819 (1992). 35. Res judicata involves two distinctive legal principles, (a) broad res judicata ("collateral estoppel" or "issue preclusion") and (b) technical or strict res judicata ("claim preclusion"). Hebden v. Workmen's Compensation Appeal Board, 142 Pa. Commw. 176,597 A.2d 182 at 187-188 (1991). 36. As stated by our Superior Court, "The purposes behind the doctrine, which bars the re-litigation of issues that either were raised or could have been raised in the prior proceeding, are to conserve limited judicial resources, establish certainty and respect for court judgments, and protect the party relying upon the judgment from vexatious judgment. In keeping with these purposes, the doctrine must be liberally construed and applied without technical restriction." [Emphasis added]. Yamulla Trucking& Excavating Co. v. Justofin, 2001 Pa. Super. 72, 771 A.2d 782, 784 (2001). 37. As stated by our Superior Court, "The doctrine of' collateral estoppel' does not require identity of causes of action or parties... [but will] bar only those issues that actually were litigated in the prior proceeding" Matternas v. Stehman, 434 Pa. Super. 255, 642 A.2d 1120 at 1125 (1994). 7 38. The doctrine of "collateral estoppel" "applies if: (1) the issue decided in the prior case . is identical to the one presented in the later case; (2) there was a final judgment on the merits; (3) the party against whom the plea is asserted was a party or in privity with a party in the prior case; (4) the party or person privy to the party against whom the doctrine is asserted had a full and fair opportunity to litigate the issue in the prior proceeding; and (5) the determination in the prior proceeding was essential to the judgment." Chada v. Chada, 2000 Pa. Super. 186, 756 A.2d 39 at 43 (2000). 39. The term privy is: merely a word used to say that the relationship between one who is a party on the record and another is close enough to include the other within the res judicata, Privity is a legal determination for the trial court as to whether the relationship between the parties is sufficiently close to support preclusion. Courts have typically found privity to exist in three circumstances: (1) where the nonparty has succeeded to, or shares a concurrent right to the party's interest in property, (2) where the nonparty controlled the prior litigation, and (3) where the party adequately represented the nonparties' interest in the prior proceeding. See First Options of Chicago Inc. v, Kaplan, 913 F. Supp. 377 at 383-384 (ED, Pa, 1996), 40. In the context of res judicata the: [d]octrine of virtual or adequate representation has been adopted by many courts. See First Options of Chicago Inc, v, Kaplan, 913 F. Supp. 377 at 383-384 (ED. Pa. 1996) citing Martin v, Wilkes, 490 U.S. 755, 761 n.2, 109 S.Ct. 2180, 2184, n,2, 104 L.Ed. 2d 835 (1989) (a nonparty may be bound if his interests are 'adequately represented by someone with the same interest who is a party'); Chase Manhattan Bank N.A. v. Celotex Corp., 56 F.3d 343, 345 (2nd Cir. 1995) ('Res judicata may be asserted when the precluded party's interest has been adequately represented in a previous lawsuit. '); Matter of L & S Indus. Inc., 989 F.2d 929, 933 (7th Cir. 1993) ('A person may be bound by a judgment even though not a party if one of the parties to the suit is so closely aligned with his interests as to be his virtual representative.'); In re Medomak Canning, 922 F.2d 895, 901 (1S! Cir. 1990) (Privity may be established by identification of interests, even where representation of those interests is not authorized.) Also see this discussion in Myers v. Kim, 55 Pa. D.&C. 4th 93 at 100-102 (Lawrence County, 2001). 8 41. In the present case the Defendant was sued for child support by two Plaintiffs before . the Cumberland County Domestic Relations Section. At the time the Defendant was held to be ~~unable to work and has no income/rom any other source" [See Order of August 11, 1997 in 641 S 84 which is attached as Exhibit "C"] the Plaintiff in the Florida action was also a Plaintiff in a pending child support case against the Defendant in Cumberland County, Pennsylvania docketed to 595 S 92. 42. The issue of whether or not Defendant could work was decided in his favor effective May 15, 1997 by Order of Court. 43. The elements of res judicata were satisfied and Defendant owed no child support to anyone including the Plaintiff after May 15, 1997. 44. Even if Florida could have exercised jurisdiction, using the judgment's own "Child Support Arrears Calculation" and the date of May 15, 1997 as the effective end of Defendant's ability to work, the judgment should have been calculated as follows in accordance with Defendant's due process rights: Year Amount 1996 $ 426.28 (September) $ 426.28 (October) $ 426.28 (November) $ 426.28 (December) 1997 $ 426.28 (January) $ 426.28 (February) $ 426.28 (March) $ 426.28 (April) $ 213.14 (May 1 - May 15) $ 3,623.38 Subtotal of Amount Due Before Disability 1998 $ 289.87 (8% Interest Using $3,623.38 Principal) 1998 $ 313,06 (8% Interest Using $3,913,25 Principal) 1999 $ 338.10 (8% Interest Using $4,226.31 Principal) 2000 $ 365.15 (8% Interest Using $4,564.41 Principal) 2001 $ 394.36 (8% Interest Using $4,929.56 Principal) 2002 $ 425.91 (8% Interest Using $5,323.92 Principal) 2003 $ 459.98 (8% Interest Using $5,749.83 Principal) 2004 $ 496.78 (8% Interest Using $6,209.81 Principal) 2005 $ 536.52 (8% Interest Using $6,706.59 Principal) 2006 $ 420.69 (8% Interest Using $7,243.11 Principal as of9/22/06) $ 7,663.80 Total Due Plaintiff Including 8% Interest from 5/15/97 9 WHEREFORE, Defendant respectfully requests this Honorable Court to strike the judgment as it violates the Defendant's due process rights since the only court of competent jurisdiction determined that as of May 15,1997 the Defendant could not work and had no income yet the judgment purports to add tens of thousands in child support allegedly due after he was disabled effective May 15, 1997. Respectfully submitted, BY: '" A St en Howell, Esq Ire owell Law Firm 619 Bridge Street New Cumberland, PA 17070 (717) 770-1277 Voice Supreme Court ID 62063 Attorney for the Defendant Certificate of Service I hereby certify that on the date set forth below a true and correct copy of the foregoing document was served upon the party/parties set forth below by postage prepaid, first class United States Mail addressed as follows: John P. Neblett, Esquire Suite 204 2000 Linglestown Road Harrisburg, P A 17110 Date: September 29,2006 10 VERIFICATION I/we verify that the statements made in the foregoing document are true and correct. I/we understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. Section 4904 relating to unsworn falsification to authorities. BY:~ . char . Bott f Date: 11 PAMELA S. BOTTORF , PLAINTIFF , vs. RICHARD E. BOTI'ORF, JR. , DEFENDANI' DR 20,196 IN THE COURT' OF ca1M)N PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA OOMESTIC RELATIONS SECTION CIVIL AcrION - SUPPORT NO. 595 OF 1992 CCMPLAINT FOR SUPPORT TO THE HOOORABLE JUIX:;ES OF SAID COURT: 1. Plaintiff resides at 655 I.ewisberry Road, New Cumberland. PA 2. Defendant resides at 108 Beach Cliff Drive, Carlisle, PA 3/24/90 at Lemoyne, PA 3. (a) Plaintiff and Defendant were married on 6-11-92 (b) Plaintiff and Defendant were separated on nla (c) Plaintiff and Defendant were divorced on at 4. Plaintiff and Defendant are the parents of the following children: ( a) Born of marriage WIFE.AND ONE CHILD Nane Lindsay M. Bottorf (b) Born out of wedlock Residence Birth Date Age ~I ~t~o 1 _1_1- _1_/- _1_1- _1_1- w/pltf _1_1- _1_1- _1_1- ("") ~n -1'~ r- ."T) f'T1 ......, I ~lJ r= . ,>C rT1 a '0 -) 'n .") --rl .. - eo ,.I . :.., ," '--' . (J J ........., .&f -.. ~ ~ DRO #140 &';;)32"- 0 0" 0.0-- ! j I EXHIBIT ~ 1~ ,I 5. Defendant has neglected the duty to support or sufficiently support the " aforerrentioned person ( s) since 6. (a) Plaintiff is (not) receiving Public Assistance in the amount of $ per', for, the ' support of (b) Plaintiff is receiving additional incare in the amount of $ per fran , 7 . A previous support order was entered against the Defendant on in an action at ( Court, TeI:m, Docket Number) in the amount of $ per for the support of There are (no) arrearages in the arrount of $ The order has (not) been tenninated. 8. Plaintiff last received support fran Defendant in the amount of $ on WHEREFDRE, Plaintiff requests that an Order be entered against Defendant and in favor of the plaintiff and the aforementioned child(ren) for reasonable support. I verify that the statements made in this Carplaint and attached lncare and Expense Statement are true and correct. I understand that false statements herein are made subject to the penalties of 18 PA C.S. 4904 relating to unsworn falsification to authorities. Dated: ~O ~ \~ -q~ c";;;) . ' Plaintif~Q~s:1d3lo:M- \ (.,., .... s.- N)TICE u Gu1.ttelines for child and spousal support have been prepared by the Court of . , ~ "" Canron Pleas and are available for inspection in the office of the Dorrestic Relations Section, 13 North Hanover Street, Carlisle, PA 17013. Additional information: DR 20,196 Pf\MELA S. BOI'I'0RF' " , PLAINTIFF IN ''iliE OJURi!:OF-':~ PLEAS OF CUMBERLAND COUNrY, PENNSYLVANIA ~ vs. AUG a 2 lJOPN t93 ~' IXl'1ESTIC RELATIONS SEX:TION CIVIL AcrION" - SUPPORr RICHARD E. l3OT'roRF ~il c-[Dl$~ C (~..~ %}r :,. :,'. ,.' .~ i:" ::~, N). 595 S . OF 1992 ,.'" . ccM>LAINT FUR SUPPORI' "r'i. 'It> THE HOOORABLE .JUIX;ES OF SAID roJRI': 1. Plaintiff resides at Apt. #9, .1 ,'t:<' 17011 2. Defendant resides at 108 Beechcliff Dr., Carlisle, PA. 17013 3. ( a) Plaintiff and D=fendant were married on 3-24-90 at Cumberland County (b) Pl~in1;iff and I:€fendant were separated on 7-19-93 (c) Plaintiff and I:€fendant \-Jere divorced on at 4. Plaintiffartd Defendant are the parents of the following children: ( a) Born of marr iage : Name Birth Date Age Residence ;LindsayM.. (197-72-7139) ~/~/~ I I --- with 'plaintiff I I --- _I_I- I I (b) Born out of wedlock I ! --- I I --- / / --- DRO #140 ! , I fXHIjjf B 'f-- '. ( Ce., ,,-, " ,>~ 5., Defendant .has"neglected the,dutyto suppoJ;1: or sufficiently support the a..forerrentioned person ( s) since 6. ( a) Plaintiff is (not) receiving Public Assistance ill the arrount of S per ,for the'support of (b) Plaintiff i..<; receiving additional incare in the amount of S r--- per fran 7 . A previous support order was entered against the Defendant on ill an act ion at (Court, Term, Docket Number) in the amount of S per for the support of There are (no) arrearages ill thearrount ofS The order has (not) been terminated. 8. Plaintiff last received supportfran D=fendant in the amount of S on WHEREFORE, Plaintiff requests that an Order be entered against D=fendant and ~n favor of the plaintiff and the aforementioned child(ren) for reasonable support. I verify that the staterrents made in this Ce>rrq;:>laint and attached lncare and Expense Statement are true and correct. I understand that false statements herein are IT6de subject to the penalties of 18 PA C.S. 4904 relating to unsworn falsification to authorities. Dated: --.J - ~L> -- Q.-:S Plajntiff~~1i)~~ l\OI'ICE Guidelines for child and spousal support have been orepared by the Court of Common Pleas and are available for inspection in the office of the Domestic Relations Section, 13 North Hanover Street, Carlisle, PA 17013. Additional information: DR I LX46 TRACEY 1. BOTTORF PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLVANIA VS DOMESTIC RELATIONS SECTION CIVIL ACTION - SUPPORT RICHARD E, BOTTORF. JR, DEFENDANT NO, 641 S X4 ORDER OF COURT AND N OW. this 11th day of August. J 997, upon the considl.;ration of the recommendation of the Domestic Relations Otllcl.;L IT IS HEREBY ORDERED AND DIRECTED that the support order be suspendl.;d et1~ctiw May IS. 1997. due to cervical spine surgery, Defendant was unable to \,vork and has no incomc from any other source, IT IS FURTHER ORDERED that defendant report on a monthly basis his medical condition. and any incoml.; from any source. The order datcd J 1/14/X6, shall bl.; reacitivated when defendant continns he is able to work. This order shall become final ten days after the mailing of the notice of the L:ntry of the order to the parties unless cithl.;r party files a \vrittl.;n demand with the Domestic Relations Section for a hL:aring dc novo bdorL: the Court. BY THE COURT. 1. DRO: Lucinda E, Shl.;utlcr cc: plaintiff dcti.:ndant :::-~"1 g en c.Ji c-:.-::;) U'i V) ;-.; 5~: EXHIBIT C I ~ --"...... (J~ .... ::3 u . TRACEY J. GORDON, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - SUPPORT DOMESTIC RELATIONS SECTION RICHARD E. BOTTORF, JR., Defendant NO, 641 SUPPORT 1984 DR 11,846 ORDER OF COURT AND NOW, this 19th day of August, 1999, testimony having been taken as to the Defendant's. ability or inability to work because of a medical condition, we do find that past medical condition continues and that at the present time he has no ability to perform gainful employment. Should the Defendant be successful in his request for social security disability income, he is directed to immediately notify the Domestic Relations Office of that situation. By the Court, Michael R. Rundle, Esquire Special Counsel for DRO Richard E. Bottorf, Jr. 405 Wren Court Mechanicsburg, PA 17055 Defendant, Pro se ~'3 ~;; r""", c..'-' Sheriff :srs EXHIIT D I u . In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS P,O. BOX 320, CARLISLE, PA. 17013 .. Phone: (717) 240-6225 Fax: (717) 240-6248 MAY 29, 1998 Member Name: RICHARD E. BOTTORF JR Docket Number: 641 S 84 PACSES Case Number: 320000076 Other State ID Number: h'.~ I'd . "~I f:. ".'~ -, , !.I' r"' ! ,!:., I '" .,. "It.;. ,: Please note: AU correspondence must include the P ACSF$ Case Number. PHYSICIAN'S INFORMATION REOUEST TO BE COMPLETED BY ATTENDING PHYSICIAN: Physician's Name: J~. ~c.d()Pl; K. r--lac;) h rn 0 Nature of patient's sickness or injury (Describe complications, if any) ~c;L('~~\ S,-P1~9 ~~~ T ~+ nl1fY'bf)~ I :\-h~ ~~ ~ I PO. .~ f'\IC ~ JeK ~ h.ead f)': Co ",tu S j("~ 1'""'\ (a) Date of first treatment: "I !q7 (b) Date of most recent treatment: 10 JdJ /9/< (c) (d) Frequency of treatments: ~("\'\-h. \ ~ Medication: ',\e ~\\\e..'" '1. c \uJ; t The patient has been continuously disabled (unable to work) from: y \ q '7 through r USa ent JD )'18 If still disabled, when should patient be able to return to work? Are there limitations? Un'<.\\owr\ --b re:hffn 'llnob\~ -10 \l~+ (Y\Cre.. ~ IOlbs. Llm.ble_-.\r>, ~\t 0\ snArl ~r lor:, rer,cxk,; need:; OSSis,-foo.CI: c:dr"JIf'Yj REMARKS: . c;: . ' Date: Signed: ~ 411.. lYS' Ian) ~q I3rLY\k L\..~ {)ve. C . Physician's Address Dr II ~/e.. PA J/O/3 I hereby authorize my physician to release the above information to the CUMBERLAND County Domestic Relations See . n /0 /~9 /98 , , Date Service Type M ! , I EXHIBIT t Form EN-015 Worker lO 21100 . . IN THE CIRCUIT COURT, NINTH JUDICIAL CIRCUIT, IN AND FOR FLAGLER COUNTY, FLORIDA CASE NO.: 96-752-CA PAMELA S. BOTTORF, Petitioner, and RICHARD BOTTORF, Respondent. / MOTION FOR TEMPORARY CHILD CUSTODY, CHILD SUPPORT, ATTORNEY'S FEES AND COSTS COMES NOW the Petitioner, PAMELA S. BOTTORF, by and through her undersigned counsel and files this Motion for Temporary Child Support, Attorney's Fees and Costs, and as grounds therefore would show: 1. Petitioner is a fit and proper person to have temporary and permanent primary residential responsibility of the minor child, LINDSAY BOTTORF, date of birth November 24, 1990. It is in the best interest of the minor child, LINDSAY BOTTORF, date of birth November 24, 1990 that the Petitioner, PAMELA S. BOTTORF be awarded temporary primary residential responsibility. Respondent is not a fit and proper person to have primary residential responsibility of the minor child. 2. Without temporary child support during the pendency of this action, the Petitioner will not be able to provide the basic necessities of life for the minor child, LINDSAY BOTTORF, date of birth November 24, 1990. 3. The Petitioner is also without adequate funds to pay the cost and attorney's fees necessary for proper representation in [i ~ F ] ~ . this case. The Petitioner will seek an award of the same at or after trial and is not waiving her claim with respect thereto. WHEREFORE, the Petitioner seeks: 1. An award of temporary primary residential responsibility of the minor child, LINDSAY BOTTORF, date of birth November 24, 1990 to the Mother with a determination with respect to visitation. 2. An award to the Petitioner of temporary child support during the pendency of this cause. 3. An award to the Petitioner of reasonable attorney's fees for proper representation in this case. LEONARD R. ROSS, ESQUIRE 434 N. Halifax Avenue, Suite 1 Daytona Beach, Florida 32118 (904) 258-5069 Florida Bar No.: 332712 CERTIFICATE OF SERVICE I HEREBY CERTIFY that the original of the foregoing has been provided to Clerk of Courts, P.O. Box 787, Bunnell, Florida 32110 and that a true and correct copy of the foregoing has been provided by U.S. Mail and facsimile to Honorable Kim Hammond, Flagler County Courthouse, P~O. Box 896, Bunne 1, FL 32110 and Ri~ard Bottorf, 405 Wren Court, Mechanicsb g, PA 17055 this day of January, 1997. LEONARD R. ROSS, ESQUIRE +- --,~------ ,-, . .. In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION PAMELA S. BOTTORF ) Docket Number 595 S 92 Plaintiff ) vs. ) P ACSES Case Number 754000020, RI CHARD E. BOTTORF JR ) Defendant ) Other State ID Number 96-752-CA ORDER AND NOW, to wit on this 5TH DAY OF JUNE, 1998 IT IS HEREBY ORDERED that the support order in this case be 0 Vacated or 0 Suspended or (i) Terminated without prejudice, effective MAY 13, 1998 , due to: THE PLAINTIFFS REQUEST TO STOP SERVICES THOUGH FLORIDA AND PENNSYLVANIA. ARREARAGE SET AT $8279.67. DEFENDANT IS TO PAY THE COSTS IN THIS MATTER IN THE AMOUNT OF $21.50 BY JULY I, 1998. BY THE COURT: DRO: lllcinda E. Sheaffer cc: Plaintiff Defendant Office of Child Support Enforcement PRES. JUDGE Service Type M ! i I EXHIBIT G Form OE-504 Worker ID 21100 ~ ~ ~ LA\.,..-' \~1 .... J-' cY C'.} <;>. 4 ? .,. ~ ~/ ,"") ( ') () It --I ;Fi;Q ",) \J:; (,) ~.Q --<: ( -" PAMELA S, DENT f/k/a PAMELA S. BOTTORF, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs, CIVIL ACTION - LAW NO. 06-4658 CIVIL RICHARD E. BOTTORF, Defendant IN RE: PETITION TO STRIKE FOREIGN JUDGMENT ORDER AND NOW, this 10" day of October, 2006, upon consideration of the foregoing petition, it is hereby ordered that: 1, A rule is issued upon the respondent to show cause why the petitioner is not entitled to the relief requested; 2. The respondent shall file an answer to the petition within twenty (20) days of service upon the respondent; 3. The petition shall be decided under Pa,R.c.p. 206,7; 4. Depositions shall be completed within forty-five (45) days of this date; 5. Argument shall be held on December 8, 2006, at 2:00 p,m. in Courtroom No.4; and 6. Notice ofthe entry of this order shall be provided to all parties by the petitioner. BY THE COURT, Ai- L S :S l'!d 0 I J.:30 9D02 .. John P. Neblett, Esquire For the Plaintiff Steven Howell, Esquire F or the Defendant :rlrn VIA OVERNIGHT MAIL October 25,2006 Prothonotary's Office Cumberland County Prothonotary 1 Courthouse Square Carlisle, P A 17013 RE: Case 06-4658 Dear Sirs: Enclosed please find my response to the Petition to Strike Foreign Judgment filed by Attorney Steven Howell at the Office ofthe Prothonotary on September 29,2006. Please place on file this response immediately and forward to the Honorable Judge Hess. There are two extra copies of this response as indicated. Please stamp each extra copy and forward as noted, I am no longer being represented by Attorney John P. Neblett in this matter. Due to the circumstances of this case, and the extreme legal costs I have incurred due to the continuing actions of the Defendant, I cannot afford to retain further legal counsel to represent me in this matter. To do so would greatly impair my ability to properly provide for the minor child on whose behalf this Judgment was brought. Therefore, I will be representing myself in this matter. Sincerely, ~ Pamela S. Dent f/k/a Pamela S. Bottorf P. O. Box 740208 Orange City, FL 32774 CC: Steven Howell, Attorney Howell Law Firm 619 Bridge Street New Cumberland, P A 17070 " VIA OVERNIGHT MAIL October 25,2006 The Honorable Judge Hess Cumberland County Court 1 Courthouse Square Carlisle, P A 17013 RE: Case 06-'4658 Your Honor: I am no longer being represented by Attorney John P. Neblett in this matter. Due to the circumstances of this case, and the extreme legal costs I have incurred due to the continuing actions of the Defendant, I cannot afford to retain further legal counsel to represent me in this matter. To do so would greatly impair my ability to properly provide for the minor child on whose behalf this Judgment was brought. Therefore, I will be representing myself in this matter. Enclosed please find my response to the Petition to Strike Foreign Judgment filed by Attorney Steven Howell at the Office of the Prothonotary on September 29,2006. Please note that Mr. Howell's Order is dated the 10th day of October, 2006. However, as indicated by the two attachments, Mr. Howell's office did not mail this package to me until October 12,2006 and the package was delivered on October 14,2006. While I am within the twenty (20) day requirement for filing my response, I feel it important to point out that the Defendant's Attorney delayed mailing the Petition for my review forcing me to respond with undue haste. I have provided Your Honor with Certified Copies of all supporting evidence and related documents. The Order for Arrest could not be certified as doing so would once again make it an active warrant. There is quite a lot of supporting evidence following. I apologize for not marking and/or indicating on any of these papers with exhibit letters/numbers to make your review of these papers less time consuming. I have been previously advised by legal counsel that these documents should not be marked in any fashion, because to do so could invalidate everything I have gone to great length to secure on such a short time frame. .. The Honorable Judge Hess Cumberland County Court Page Two October 25,2006 Regarding the hearing scheduled for December 8, 2006 at 2:00 pm, I respectfully request that you allow me to attend this hearing telephonically. I cannot afford to take off unpaid time from work to personally attend this hearing nor pay the costs involved with traveling to Pennsylvania. In addition, I fear for my safety if I were forced to attend this hearing in person. To this day I live in fear of the Defendant, and those around him, who might seek to do me harm because of threats directed to me by the Defendant in the past. This is why there is a permanent injunction in place in the State of Florida. Your Honor, if I cannot be allowed to attend the December 8, 2006 2:00pm hearing telephonically I respectfully request that you reschedule this hearing and grant me a sixty (60) day extension. This time will be needed for me to arrange time off from work, make all necessary travel plans with personal protection being in place for me before I arrive and during my time in Pennsylvania. Sincerely, Pamela S. Dent f/k1a Pamela S. Bottorf P. O. Box 740208 Orange City, FL 32774 /pd 2 Attachments CC: Steven Howell, Attorney Howell Law Firm 619 Bridge Street New Cumberland, PA 17070 III w .. .... .... ... ~ i . c UI "C UI (, o 3 " ... rn :t- en rn " ::l:I rn en en ." i 3!: ... "< ~':i".'...""~.,':- ,i:; "~~" . i '1::i ~ C"), ~ ~ Q CI) at 1 ~ s. CD " ... ~ en rn " ::l:I rn en en ." i 3!: ... C> C> C> C> gt;B g..r:::::.. ~ 'i't..n C> ....00 n R :D ~:~;. C:N"""-' z. -rc .... -r C> . en "ll :D ~. ..,l.. '" 1JI..,.Q.$....~. and is provided solely for use in sending Priority MaiI4'J. ........ ifF JBtx.raty 2006 USPS ALL RIGHTS RESERVED USPS - Track & Confirm Page 1 of 1 . .. HOIll!! I Help Track & Confirm Search Results Label/Receipt Number: 0305 0830 0002 0270 9096 Status: Delivered Track & Confirm Your item was delivered at 7:15 am on October 14, 2006 in ORANGE CITY, FL 32774. Enter Label/Receipt Number. L ( AddifioIMI DetltilJ >) (Rt1Ium _ fI'$PS.i:tJfIIlhHne > ) NOOfi~ Track & Confirm by email Get current event information or updates for your item sent to you or others by email. . POSTAL INSPECTORS Preserving the Trust site map contact us government services Jobs National & Premier Accounts Copyright @ 1999-2004 USPS. All Rights Reserved, Terms of Use Privacy Polit::Y http://trkcnfrm1.smi.usps.comJPTSlntemetWeb/lnter LabelInquiry .do 10/2312006 PAMELA S. DENT f/k/a PAMELA S. BOTTORF Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PENNSYLVANIA VS. RICHARD E. BOTTORF Defendant NO. 06-4658 PLAINTIFFS RESPONSE TO PElT ION TO STRIKE FOREIGN JUDGMENT Identification of the Parties: 1. Agreed 2. Agreed 3. Agreed Summary of Petition: 4. Denied. This $34,373.46 judgment stems from Plaintiffs child support action for the period of September 1, 1996 through June 20, 2001 as well as legal expenses of $750.00 awarded at the final divorce hearing of May 21, 1998 (see page 9 lines 7-20 of following Certified Court Transcript) and medical expenses of $436.28 awarded at the final divorce hearing of May 21, 1998 (see page 12 lines 9-21 of following Certified Court Transcript) by the Honorable Judge Kim C Hammond and the continuing interest due on the unpaid child support, unpaid legal expenses and unpaid medical expenses as allowed by law and determined by the Florida court. This is evidenced by the following Certified Copy of the Court Transcripts and the following Certified Copy of the Final Judgment of Dissolution of Marriage and by the following Certified Copy of the Final Judgment. 1 Plaintiff did file a Complaint for Support on June 18, 1992 and again on August 3, 1993 with the Domestic Relations section of Cumberland County while Plaintiff and minor child were residents of Pennsylvania. Both Complaints for Support were properly closed, as instructed by the Domestic Relations Section of Cumberland County, by the Plaintiff on August 26, 1993 and on July 9, 1992 as evidenced by the Certified Copies following, No further services were obtained by, nor provided to the Plaintiff from the Domestic Relations Section of Cumberland County on either Complaint for Support. No hearing was held on either Complaint for Support by the Domestic Relations Section of Cumberland County nor was any support order entered on behalf of the minor child by the Domestic Relations Section of Cumberland County. Plaintiff and minor child relocated to Flagler County Florida on April, 19, 2006. After Plaintiff and minor child resided in Flagler County Florida for a period of six months Plaintiff and minor child were legally considered residents of the State of Florida. (see page 16 lines 4-22 of following Certified Court Transcript). On January 7, 1997 Plaintiff filed Motion for Temporary Child Custody, Child Support, Attorney's Fee's and Costs with the Flagler County Court a Certified Copy of which follows. A hearing was scheduled for February 11, 1997. A hearing was held on February 11, 1997 before the Honorable Kim C. Hammond during which a Child Support Obligation was entered against the Defendant. This is evidenced by the following Certified Copy of the Notice of Hearing and the Certified copy of the Order. 2 Subsequently Plaintiff then brought a new action originated in Florida and thru the Florida Dept of Revenue. This action was sent was to the Domestic Relations Section of Cumberland County by the Florida Dept of Revenue for enforcement as Defendant was a resident of Pennsylvania. This is evidenced by the following Certified Copy of the Cumberland County Court Order dated January 29, 1998 confirming that a Florida Child Support order was registered for enforcement. This action was terminated on June 5, 1998 as required by agreements reached between the Defendant and the Plaintiff at the final divorce hearing held before the Honorable Judge Kim C. Hammond of the Flagler County Court on May 21, 1998 (see page 8 lines 4-25 and page 9 lines 1-6 of following Certified Court Transcript). This is evidenced by the following Certified Copy of the Court Transcripts and by the following Certified Copy of the Final Judgment of Dissolution of Marriage. During the final divorce hearing held on May 21, 1998 and before the Honorable Judge Kim C. Hammond of the Flagler County Court the Defendant did personally, freely, voluntarily and without hesitation agree to submit to the jurisdiction of Florida on all issues contained in and relating to the matter of the dissolution of marriage, the issues of child custody, visitation and support and the enforcement thereof (see page 3 lines 6-18 of following Certified Court Transcript). At this same hearing the child support arrearages, monthly on going support amount (see page 4 lines 1 8-25 and page 5 lines 1-2, page 8 lines 4-25 and page 9 lines 1-6, of following Certified Court transcript) legal expenses (see page 9 lines 7-20 of following Certified Court Transcript) and medical expenses were awarded (see page 12 lines 9-21 of following Certified Court Transcript). This is evidenced by the following Certified Copy of the Court Transcripts and by the following Certified Copy of the Final Judgment of Dissolution of Marriage. 3 Defendant did personally appear and did personally, freely, voluntarily and without hesitation consent to Florida jurisdiction before the Court during the hearing held on May 21, 1998 (see page 3 lines 6-18 of following Certified Court Transcript). Therefore Defendant's due process rights were not violated by the State of Florida and the Florida Judgment should not be stricken. This is evidenced by the following Certified Copy of the Court Transcripts and by the following Certified Copy of the Final Judgment of Dissolution of Marriage. Furthermore, any issues relating to the Defendants Medical or Disability Issues and how they relate to and affect this Judgment would be addressed with the Flagler County Florida Court. Factual Background: 5. Agreed, 6. Denied. This $34,373.46 judgment stems from Plaintiff s child support action for the period of September 1, 1996 through June 20, 2001 as well as legal expenses of $750.00 awarded at the final divorce hearing of May 21, 1998 (see page 9 lines 7-20 of following Certified Court Transcript) and medical expenses of $436.28 awarded at the final divorce hearing of May 21,1998 (see page 12 lines 9-21 of following Certified Court Transcript) by the Honorable Judge Kim C Hammond and the continuing interest due on the unpaid child support, unpaid legal expenses and unpaid medical expenses as allowed by law and determined by the Florida court. This is evidenced by the following Certified Copy ofthe Court Transcripts and the following Certified Copy of the Final Judgment of Dissolution of Marriage and by the following Certified Copy of the Final Judgment. 4 7. Agreed. 8. Agreed. 9. Agreed. 10. Agreed. 11. Denied. Both of the prior Complaint for Support requests filed with the Domestic Relations Section of Cumberland County were properly closed, as instructed by the Domestic Relations Section of Cumberland County, by the Plaintiff. See following Certified Copies. 12. Denied. The Honorable George E. Hoffer's order regarding Defendant has no bearing on on the Florida Judgment. Florida retains all Jurisdiction on this case, arrearages and expenses awarded were set by the Honorable Judge Kim C. Hammond in Flagler County Court and agreed to by the Defendant on May 21, 1998 (see page 3 lines 6-18 of following Certified Court Transcript). At no time during the hearing held on May 21, 1998 before the Honorable Kim C. Hammond did the Defendant address or enter into evidence any information regarding his alleged disability. This is evidenced by the following Certified Copy of Court Transcripts and the following Certified Copy of Final Judgment of Dissolution Marriage. 13. Denied. The Honorable George E. Hoffer's hearing regarding Defendant has no bearing on the Florida Judgment. Florida retains all Jurisdiction on this case as agreed to by the. Defendant on May 21, 1998 (see page 3 lines 6-18 of following Certified Court Transcript). This is evidenced by the following Certified Copy of Court Transcripts and the following Certified Copy of Final Judgment of Dissolution Marriage. 5 . 14. Denied. Defendants Physician finding has no bearing on the Florida case. See Certified Copy of Court Transcripts and Certified Copy of Final Judgment of Dissolution Marriage following. 15. Denied. The August 19, 1999 Order issued by Cumberland County on Defendants Child Support Case DRl1846 Tracey J. Gordon v. Richard E. Bottorf, Jr. has no bearing on the Florida Judgment. Florida retains all Jurisdictions on this case, arrearages and expenses awarded were set by the Honorable Judge Kim C. Hammond in Flagler County Court and agreed to by the Defendant on May 21, 1998 (see page 3 lines 6-18 of following Certified Court Transcript). This is evidenced by the following Certified Copy of Court Transcripts and the following Certified Copy of Final Judgment of Dissolution Marriage. 16. Denied. Defendant At no time did the Defendant take any action to have the Child Support obligation in the State of Florida amended, reduced, cancelled or suspended. At no time did the Defendant submit any proof of his alleged total disability to Florida courts. Defendant had every opportunity to submit such proof during the court hearing held on May 21,1998 as well as the hearing held on November 9, 1998 (see Order dated November 17, 1998) and October 21, 1999 (see Order dated November 3, 1999). Also it should be noted by the Court that the Plaintiff has questioned the Defendants statements as regards that he has had no income commencing on May 15, 1997 to the Honorable Kim C. Hammond. During the hearing held on November 9, 1998 the Defendant did willingly advise The Honorable Kim C. Hammond, while under oath, that he (a) had applied for Social Security benefits which had been approved and payment to the minor child were forthcoming (b) he owned no property and (c) he owned no vehicles. 6 Subsequently and during the hearing held on October 21, 1999 the Plaintiff did show proof to the Honorable Kim C. Hammond that the Defendant had willfully, intentionally and freely made several false statements to the court during the prior hearing held on November 9, 1998. The Plaintiff was able to advise and show the court that (a) Plaintiff had called the Social Security Administration several times. Each time the Plaintiff had been advised that, while the Defendant had applied for Social Security Disability benefits, he had been denied benefits each time. At the time of the hearing held on November 9, 1998 the Defendant had not been approved for benefits and no benefits were forthcoming to the minor child. (b) Defendant owned two homes. Defendant had owed the home located at 405 Wren Court, Mechanicsburg, P A since May of 1996. Also, Defendant had purchased the property located at 617 Bridge Street, New Cumberland, P A on October 7, 1998. This home was purchased in the Defendants sole name. This home purchase was made less than one month before the hearing held on November 9, 1998. (c) Defendant had purchased a new 1998 Chevrolet, S#2G1 WX12K.XW9323294, on September 2, 1998. This vehicle was purchased in the Defendants sole name. This vehicle was purchased less than two months before the hearing held on November 9, 1998. Plaintiff was able to show these facts to the Honorable Kim C. Hammond by way of Certified Copies of Property Deeds, obtained from the Cumberland County Court House on September 3, 1999, and by Certified Copies of Vehicle Record Abstracts Dated 9/01/99 and 9/07/99 from the Pennsylvania Department of Transportation. Copies of these documents follow for the courts review. The originals have been retained by the Flagler County Courts. 7 The Plaintiff questioned the Defendants Legal Counsel how the Defendant could afford to purchase a new home, maintain an existing home, and purchase a new vehicle while being disabled and incapable to work and having no income. The Defendants Legal Counsel was unable to answer the Plaintiff's question. Therefore, the Honorable Kim C. Hammond found in favor of the Plaintiff and found that, given the Certified Copies and proof provided by the Plaintiff, that the Defendant had knowingly made numerous false statements to the court during the hearing held on November 9, 1998. The Defendant was found to be in contempt of Court and an order so noting this fact was thereby entered into court on November 3, 1999. Subsequently an Order for Arrest against the Defendant was entered into the court on February 16,2000. This is evidenced by the following Certified Copy of Court Transcripts and the following Certified Copy of Order dated November 17, 1998 and the following Copy of Order Dated November 3, 1999. 17. Agreed. 18. Denied. Both Complaints for Support were properly closed, as instructed by the Domestic Relations Section of Cumberland County, by the Plaintiff on August 26, 1993 and on July 9, 1992 as evidenced by the Certified Copies following. No further services were obtained by, nor provided to the Plaintiff from the Domestic Relations Section of Cumberland County on either Complaint for Support. No hearing was held on either Complaint for Support by the Domestic Relations Section of Cumberland County nor was any support order entered on behalf of the minor child by the Domestic Relations Section of Cumberland County. Since Plaintiff moved to Florida on April 19, 1996 and after 8 Plaintiff and minor child resided in Flagler County Florida for a period of six months Plaintiff and minor child were legally considered residents of the State of Florida (see page 16 lines 4-22 of following Certified Court Transcript). Therefore, it was entirely legal and proper for Plaintiff to file a new action in the State of Florida. 19. Denied. Hearing was held on February 11, 1997. The subsequent order was entered on February 27, 1997. This is evidenced by the following Certified Copy of Notice of Hearing and following Certified Copy of Order dated November 17, 1998 20. Denied. Plaintiff did notify her legal counsel accordingly. Since Attorney/Client conversations are privileged, neither Defendant or his Attorney would be privy to this fact and any assumptions otherwise serve only to paint Plaintiffs actions in a negative fashion to this Honorable Court. However, since both Complaints for Service to the Domestic Relations Section of Cumberland County had been properly closed and, since Plaintiff and the Minor Child were now legal residents of the State of Florida (see page 16 lines 4-22 of following Certified Court Transcript), it was entirely legal and proper for Plaintiffs Attorney to file a new action in the State of Florida. 21. Agreed. 22. Denied. Both Complaints for Support were properly closed, as instructed by the Domestic Relations Section of Cumberland County, by the Plaintiff on August 26, 1993 and on July 9, 1992 as evidenced by the Certified Copies following. No further services were obtained by, nor provided to the Plaintiff from the Domestic Relations Section of Cumberland County on either Complaint for Support. No hearing was held on either 9 Complaint for Support by the Domestic Relations Section of Cumberland County nor was any support order entered on behalf of the minor child by the Domestic Relations Section of Cumberland County. 23. Agreed in part. This action was terminated on June 5, 1998 as required by agreements reached between the Defendant and the Plaintiff at the final divorce hearing held before the Honorable Judge Kim C. Hammond of the Flagler County Court on May 21, 1998 (see page 8 lines 4-25 and page 9 lines 1-6 of following Certified Court Transcript). This is evidenced by the following Certified Copy of the Court Transcripts and by the following Certified Copy of the Final Judgment of Dissolution of Marriage. 24. Denied. Plaintiff withdrew her action in late May/early June of 1998 as required by agreements reached between the Defendant and the Plaintiff at the final divorce hearing held before the Honorable Judge Kim C. Hammond of the Flagler County Court on May 21,1998 (see page 8 lines 4-25 and page 9 lines 1-6 of following Certified Court Transcript). This is evidenced by the following Certified Copy of the Court Transcripts and by the following Certified Copy of the Final Judgment of Dissolution of Marriage. 25. Denied. Plaintiff did not secretly pursue the action in Florida. Pennsylvania had no further jurisdiction over the Plaintiff or Minor Child as of October 11, 1996 as they were legal residents of the State of Florida (see page 16 lines 4-22 of following Certified Court Transcript). In addition (a) Both Complaints for Support were properly closed, as instructed by the Domestic Relations Section of Cumberland County, by the Plaintiff on August 26, 1993 and on July 9, 1992 as evidenced by the Certified Copies following. No further services were obtained by, nor provided to the Plaintiff from the 10 Domestic Relations Section of Cumberland County on either Complaint for Support. No hearing was held on either Complaint for Support by the Domestic Relations Section of Cumberland County nor was any support order entered on behalf of the minor child by the Domestic Relations Section of Cumberland County. (b) during the final divorce hearing held on May 21, 1998 and before the Honorable Judge Kim C. Hammond of the Flagler County Court the Defendant did personally, freely, voluntarily and without hesitation agree to submit to the jurisdiction of Florida on all issues contained in and relating to the matter of the dissolution of marriage, the issues of child custody, visitation and support and the enforcement thereof (see page 3 lines 6- 18 of following Certified Court Transcript). At this same hearing the child support arrearages, monthly on going support amount (see page 4lines18-25 and page 5 lines 1-2, page 8 lines 4-25 and page 9 lines 1-6, of following Certified Court transcript) legal expenses (see page 9 lines 7-20 of following Certified Court Transcript) and medical expenses were awarded (see page 12 lines 9-21 of following Certified Court Transcript). This is evidenced by the following Certified Copy of the Court Transcripts and by the following Certified Copy of the Final Judgment of Dissolution of Marriage. 26. Denied in part. Plaintiff was aware that Defendant was claiming to be totally disabled however at no time did the Defendant submit any proof of his alleged total disability to Florida courts. Therefore, this was not an issue addressed in the court having jurisdiction on this matter. Defendant had every opportunity to submit such proof during the court hearing held on May 21, 1998 as well as the hearing held on November 9, 1998 (see Order dated November 17, 1998) and October 21, 1999 (see Order dated November 3, 1999) oftime"noted nor did Plaintiff have any support case open in Pennsylvania. Both Complaints for Support were properly closed, as instructed by the Domestic Relations 11 Section of Cumberland County, by the Plaintiff on August 26, 1993 and on July 9, 1992 as evidenced by the Certified Copies following. No further services were obtained by, nor provided to the Plaintiff from the Domestic Relations Section of Cumberland County on either Complaint for Support. No hearing was held on either Complaint for Support by the Domestic Relations Section of Cumberland County nor was any support order entered on behalf of the minor child by the Domestic Relations Section. Plaintiff did bring a new action originated in Florida and thru the Florida Dept of Revenue. This action was sent was to the Domestic Relations Section of Cumberland County by the Florida Dept of Revenue for enforcement as Defendant was a resident of Pennsylvania. Defendant was fully aware of the arrearages and awards that were set by the Honorable Judge Kim C. Hammond in Flagler County Court and agreed to by the Defendant on May 21, 1998. See Certified Copy of Court Transcripts and Certified Copy of Final Judgment of Dissolution Marriage following. 27. Denied. Plaintiff did discontinue her Florida child support case, which was filed with the Florida Department of Revenue and sent to Domestic Relations in Cumberland County Pennsylvania for enforcement, as she agreed to do during the hearing of May 21, 1998 (see page 8 lines 4-25 and page 9 lines 1-6 of following Certified Court Transcript), This is evidenced by the following .originalletter dated November 16, 1998 from Pat Clark, Revenue Service Center Manager, with the State of Florida Dept of Revenue. However, Plaintiffs agreement during the hearing of May 21, 1998 to close the open enforcement case did not close or eliminate the Child Support Obligations of the Defendant. Rather the method of payment for the Defendants Child Support Obligation was to be amended, with the Child Support Obligation being paid through the Clerk 12 of Court, Flagler County (see page 8 lines 4-25 and page 9 lines 1-6 of the following Certified Court Transcript). This is evidenced by the following Certified Copy ofthe court transcripts and by the following Certified Copy of the Final Judgment of Dissolution of Marriage. Furthermore, at no time did Plaintiff secretly keep the Florida case open with the intent of accruing tens of thousands of dollars in unpaid child support. The Child Support obligations of the Defendant continued to remain in effect in the State of Florida until the Plaintiff started receiving payment from the Social Security Administration to satisfy the Defendants continuing obligation (see page 8 lines 4-25 and page 9 lines 1-6 of following Certified Court Transcript). At no time did the Defendant take any action to have the Child Support obligation in the State of Florida amended, reduced, cancelled or suspended. At no time did the Defendant submit any proof of his alleged total disability to Florida courts. Defendant had every opportunity to submit such proof during the court hearing held on May 21, 1998 as well as the hearing held on November 9, 1998 and November 3, 1999, The Defendant continued to be fully aware of the Plaintiff's continuing efforts to receive the Child Support obligation awarded by the first subsequent hearing held on November 9, 1998 during which Defendant attended telephonically and again during the second subsequent hearing held on October 21, 1999 during which the Defendant was represented by legal counsel. This is evidenced by the following Certified Copy of Order dated November 17, 1998 and the following Copy of Order Dated November 3, 1999. 13 In addition, and as a result of the hearing held on November 3, 1999, an Order for Arrest was issued to the Sheriffs of the State of Florida as regards the Defendant. Again, the Defendant did not submit any proof to the Florida Courts of his alleged total disability. This is evidenced by the following Copy of the Order for Arrest. The Defendant had numerous opportunities to submit proof of his alleged total disability to the Florida courts on several occasions and did not. Defendant has been given full credit by the Florida Court for all payments received from the Social Security Administration towards his Child Support obligation. This is evidenced in the calculations attached to the Florida Judgment dated September 13,2005. 28. Denied. Plaintiff did not attempt an "end run" to the State of Florida but was a legal resident of the State of Florida and, as such, legally and rightfully filed her petition in the State of Florida on behalf of the minor child who was also a resident of the State of Florida. After October 19, 1996 the State of Pennsylvania had no further jurisdiction over the Plaintiff, minor child or any legal issues involving either party as both were legal residents of the State of Florida (see page 16 lines 4-22 of following Certified Court Transcript). 29. Denied. Defendant supplied no proof of his alleged total disability in April of 1997 to the Florida Courts to thereby relieve his Child Support obligation. To date, no such proof has been provided to the Florida Courts which continue to have jurisdiction over this case as agreed to by the Defendant on May 21, 1998 (see page 3 lines 6-18 of following Certified Court Transcript). This is evidenced by the following Certified Copy of the court transcripts and by the following Certified Copy of the Final Judgment of Dissolution of Marriage. 14 . 30. Agreed. 31. Agreed in part. The minor child legally became a resident of Florida on October 19, 1996 Florida (see page 16 lines 4-22 of following Certified Court Transcript). 32. Denied in part. Plaintiff moved to Florida with the minor child on April 19, 1996. Petition to Strike Should Not Be Granted as the Florida Judgment Does Not Violate The Defendant's Right to Due Process as the Defendant did personally, freely, voluntarily and without hesitation agree to submit to the jurisdiction of Florida on all issues contained in and relating to the matter of the dissolution of marriage, the issues of child custody, visitation and support and the enforcement thereof. The Defendant had numerous opportunities to submit proof of his alleged total disability to the Florida courts on several occasions and did not. This case stands separate of any other case or action held in Pennsylvania or any other State regarding the Defendant. To strike the Foreign Judgment based on a hearing involving the Defendant and any other case would violate Plaintiff's rights, as a valid and enforceable Judgment was entered by the court which had, and continues to have, Jurisdiction over this matter as agreed to by the Defendant. 33. Agreed. At no time was there a lack of due process or opportunity to defend or absence of jurisdiction as regards this Defendant. Therefore enforcement of this foreign judgment should be allowed. During the final divorce hearing held on May 21, 1998 and before the Honorable Judge Kim C. Hammond of the Flagler County Court the Defendant did personally, freely, voluntarily and without hesitation agree to submit to the jurisdiction of Florida on all issues contained in and relating to the matter of the dissolution of marriage, the issues of child custody, visitation and support and the enforcement thereof. At this same hearing 15 the child support arrearages, monthly on going support amount, legal expenses and medical expenses were awarded. This is evidenced by the following Certified Copy of the court transcripts and by the following Certified Copy of the Final Judgment of Dissolution of Marriage. 34. Agreed. At no time was there a lack of subject matter jurisdiction, a lack of jurisdiction over the parties, a violation of either party's due process rights, or a lack of meaningful opportunity to appear and defend as regards this Defendant. Therefore enforcement of this foreign judgment should be allowed. During the final divorce hearing held on May 21, 1998 and before the Honorable Judge Kim C. Hammond of the Flagler County Court the Defendant did personally, freely, voluntarily and without hesitation agree to submit to the jurisdiction of Florida on all issues contained in and relating to the matter of the dissolution of marriage, the issues of child custody, visitation and support and the enforcement thereof. At this same hearing the child support arrearages, monthly on going support amount, legal expenses and medical expenses were awarded. This is evidenced by the following Certified Copy of the court transcripts and by the following Certified Copy of the Final Judgment of Dissolution of Marriage. 35. Denied. Pennsylvania has no jurisdiction over issues surrounding this case. This case and all matters related to this case fall under the jurisdiction of the State of Florida. 36 & 37. Denied. Pennsylvania has no jurisdiction over issues surrounding this case and all matters related to this case fall under the jurisdiction of the State of Florida. There has been no re-litigation of any issues raised in any prior proceedings. Rather the issues and facts of this case are entirely separate of any other case involving the Defendant. 16 38. Denied. "Collaterial Estoppel" does not apply in this case as (1) the issue decided in the prior case was not presented and/or addressed in the later case; (2) there was no final judgment on the merits of the issue decided in the prior case as it was not presented (3) privy does not apply to this case (4) the Defendant was provided a full and fair opportunity to litigate any issues (5) the determination in the prior proceeding was not presented by Defendant or his legal counsel to the Florida court. In addition, Defendant agreed to Florida jurisdiction in this matter. This case stands separate of any other case or action held in Pennsylvania or any other State regarding the Defendant. 39. Definition of term. 40. Definition of term. 41. Denied. Defendant was sued for child support by only one Plaintiff before the Cumberland County Domestic Relations Section. Plaintiff Complaints for Support were properly closed, as instructed by the Domestic Relations Section of Cumberland County, by the Plaintiff on August 26, 1993 and on July 9, 1992 as evidenced by the Certified Copies following. No further services were obtained by, nor provided to the Plaintiff from the Domestic Relations Section of Cumberland County on either Complaint for Support. No hearing was held on either Complaint for Support by the Domestic Relations Section of Cumberland County nor was any support order entered on behalf of the minor child by the Domestic Relations Section. 42. Agreed in part. This determination was made as regards the case of Child Support Case DR11846 Tracey J. Gordon v. Richard E, Botto1f, Jr. and has no bearing on the case held under Florida jurisdiction. 17 43. Denied. 44. Denied. Defendant's personal Attorney in Pennsylvania is obviously not fully aware of all matters relating to this case as evidenced by statements made herein, and therefore has no basis or right to determine what is due to the Plaintiff. Determination of the amount of the judgment due Plaintiff was made by the Honorable Kim C. Hammond who has jurisdiction in this case and in full accordance with Florida laws. Defendant personally attended and was represented by legal counsel during this process and therefore did not suffer any injuries to his due process rights. Furthermore, Defendant may have been unable or unwilling to work while recuperating from surgery related to an alleged prior injury although this temporary alleged disability does not preclude Defendant from ever being gainfully employed and/or having income. Defendant owns several rental properties and operates "Bottorf Rentals", a for-profit Business (as evidenced in the following Certified Answer of Respondent To Motion For Writ OfNE Exeat and For Contempt and Motion to Quash Writ dated July 11,2005) which, as related to Plaintiff in electronic mail, "I DID NOT REALIZE HOW COMPLICATED I VE BECOME. RENTS ARE DUE ON LAST OF MONTH, CANT TRUST JUST ANYBODY TO MAKE THE DEPOSITS A LOT OF IT IS CASH." (as evidenced by the following copy of Defendants email dated Wednesday, 29 June 2005). Insofar as Defendant has made many false or incomplete statements to this Honorable Court, Defendant may also be hiding from the court other income from, but not limited to, stocks, bonds, investments, business involvements, lottery winnings, trust funds, wills, estate settlement, inheritances, etc. 18 I. WHEREFORE, Plaintiff respectfully requests this Honorable Court uphold the foreign judgment entered against the Defendant. Defendant's right to due process were not violated. The court with jurisdiction over this matter is Flagler County Florida as personally agreed to by the Defendant. Defendants support obligations continued to be due to the minor child, who is a legal resident of Florida and therefore represented by her Mother before the Florida courts, until such time that Social Security Administration payments fully satisfied this obligation. Defendant has been given full credit by the Florida Court for all payments received from the Social Security Administration towards his Child Support obligation. This is evidenced in the calculations attached to the Florida Judgment dated September 13,2005. At no time did the Defendant take any action to have the Child Support obligation in the State of Florida amended, reduced, cancelled or suspended. At no time did the Defendant submit any proof of his alleged total disability to Florida courts. Plaintiff has recently contacted the Federal U.S. District Court, Middle District of Florida, to ascertain if the Defendant is also in violation of, and can be prosecuted under, The Deadbeat Parents Punishment Act (DDPA) of 1998 which makes willful failure to pay a past due support obligation, with respect to a child residing in another state, a federal offense.F 19 In addition, the Plaintiff respectfully requests that this Honorable Court hold the Defendant in Contempt for knowingly making false statements and incomplete statements in the Petition to Strike Foreign Judgment and causing Plaintiff, and the minor child, further mental anguish and unnecessary expense according to 18. Pa. C.S.A. Section 4904 relating to unsworn falsification to authorities. Respectfully submitted, ~~~\)~ Pamela S. Dent flk/a Pamela S. Bottorf, Plaintiff P. O. Box 740208 Orange City, FL 32774 Certificate of Service Plaintiff does hereby certify that on the date set below a true and correct copy of the foregoing document was served upon the party set forth below by prepaid, Federal Express Overnight service, addressed as follows: Steven Howell, Esquire Howell Law Firm 619 Bridge Street New Cumberland, P A 17070 ~ Pamela S. Dent flk/a Pamela S. Bottorf, Plaintiff Date: October 25, 2006 20 UK CXU'!'/0 I FORM C ~OJ\\'(H a~oHol-~ v~\0J\al-d ~()\-\ol-~ ~I I, ~Um QAO ~Ono t- ~ ' desire that no further be taken on my application for support from ~ \ 0 A\ Q \-6 ~ 0\10 \-~ ]' " at this time due to the fact that \>Q,~\ O-b ~ \l Q \-0 CO t\ C i \9 d When I desire to pursue support, I will notify the Domestic Relations Office in ~lit~~g. 2C t i-::c 7Jfn1/;Y :I/~ Date: 1- Cl9 d ~Y~Q~ App lican A TRUE CI0PY r..'f'l(I()M f"..ECOAD In T~~'!I",.)N;..,>.,~".,'M'" ,u<'.~ ~ hMd ... ~_ ~1':"" \;;A "~iH' :~.."...., !II: ,.'..'~. Fla. Tl*);1~~~~ \..1I:,i';1,: ot'~ ; ,;;; <",\':'I!'ls ~~tH 'r .. CDlIIIr ~i~jT~~;,:':;:;I.:L,";~:::';",~~;jT Parrela Bottorf FORM C j)l:!.~ v. Richard Bottorf I. PflTT\P.li'l Bottorf be taken on my application for support from at this time due to, the When I desire to pursue . tjpJ/fI/ tj~ffL IW1tness Date: f -:::Lb --93 r , ORO, #.735 desire that no further actic~ Richard Bottorf f,act that X U%l:OiffiQn\- ~~..-...Mj'Q.oll ~rMb support, I will noti~me~s Office in writ:.::g. ~G;J(t~ p11cant . A TAlJE (X)fIY f'W)M RE<X:R1 In T~o~ '~'C,,; ! i~. ...~ &<< *tiJ hMd .. ~lW ~~~" o..-.a~ \.:....,~;, flu. na~1: ~'\ '~,.,~~~ C(~p 08;10; ot CouItI ~ IdlllltCiowltJ ~ 1~1 ,~, r,,:; C't">-~.l~ .D~~~,;i'l,,,i;~~<l'-1"" "~'''''''''' '~'> ~,' c'""...;etl o;;*,"",.''H.~:T ~~YU"'''''''''''''-;J "",,,., "'" ~lf.1:t, ~",,"'>>ff iii .. .. . PAMELA S. BOTTORF, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. DOMESTIC RELATIONS SECTION RICHARD E. BOTTORF, JR., 595 SUPPORT 1992 Defendant DR 20,196 IN RE: SUPPORT ORDER OF COURT AND NOW, January 29, 1998, 3:20 p.m., after consideration of the argument presented, we direct that the Florida order be registered in Pennsylvania. By the Court, D.R.O/ Michael R, Rundle, Esquire For D.R.O. Richard E. Bottorf, Jr., Defendant 405 Wren Court Mechanicsburg, Pa. 17055 Sheriff :mtf A TRUE COpy FRO~,'" RECORD In Te3tl;v;'^ and tl', ;' ~ hand ~JdJ:!J9~ ;',;'..Irts ".lie i,A.,Utlty '~. .OCJ::L~ Cisrk 01 Courts Cumbei1ud C0, <}C:~mr.:~:lon expIreS FirM ~(, ".';':" ," ,>:",,"''1 d)_~ CHILD SUPPORT ENFORCEMENT ACKNOWLEDGEMENT ~ \(~\(l~, c1 ~tJ I ~p r t'l,?' ~( PLAIRT'/'-ET!:liiONER STM'E 5" FLORIDA, DEPT. OF REVENUE O/B/O PAMELA S BOTTORF SSM: 174-46-5194 DEFBRI>ABr/RESPONDENT RICBAllD E BO'l'TORF JR SSM: 168-48-3931 FIPS PJlCM: OTHER STATE CENTRAL REGISTRY, CODE COURl' OR AGENCY (ADDRESS) DOMESTIC RELATIONS SECTION 420410 CUMBERLAND COUNTY COURTHOUSE, P. O. BOX 320 CARLISLE PA 17013 TO: FLORIDA CONTACT PERSON (AGENCY AND ADDRESS) OFFICE OF CHILD SUPPORT ENFC. INTERSTATE UNIT FLAGLER CO. 1823 BUSINESS PARK BLVD. DAYTONA BEACH FL 32114 FIPS CODE 120350 (X) IV-D NON AFDC ( ) IV-D AFDC/IV-E FOSTER CARE ( ) NON IV-D INITIATING CASE/DOCKET NO. 96 -7SC)..Cft- COUNTY/STATE FLAGLER/FL OTHER REFERENCE NO. FILE STAMP RESPONDING CASE/DOCKET NO. 754000020 COUNTY /STATE CUMBERLAND/PA OTHER REFERENCE NO. I . ACTION REQUESTED IF COLLECTION LOCATION IS NEW OR DIFFERENT LIST IN SECTION VI, PAGE 2. (X) PLEASE RETURN THE ACKNOWLEDGMENT ATTACHED 1. ( ) LOCATION OF: A. ( ) ABSENT PARENT C. B. ( ) EMPLOYER AND WAGES D. 7. ( ) ENFORCEMENT OF EXISTING ORDER (URESA) ASSETS OTHER INFORMATION TO ASSIST IN LOCATION (URESA) 8. REGISTRATION OF FOREIGN SUPPORT ORDER (URESA) 2. ESTABLISHMENT OF PATERNITY 3. ( ) A. B. ESTABLISHMENT OF ORDER ( ) CHILD SUPPORT ( ) SPOUSAL SUl'PORT (NON IV-D ONLY) (URESA) FOR: 10. D. ( ) MEDICAL COVERAGE E. ( ) OTHER COSTS (E.G., DELIVERY, 11. OTHER MEDICAL, GENETIC TESTING COSTS: ATTORNEYS' FEES) ADMINISTRATIVE REVIEW FOR FEDERAL TAX OFFSET C. ( ) UNREIMBUMED PUBLIC ASSISTANCE (IN IV-D CASES, T"dE AM:)\1N'l' MUST BE REDUCED TO A CHILD SUPPORT JUDGEMENT.) 9. CHANGE OF PAYEE (E.G., AFDC STATUS CHANGE) REDIRECT PAYMENT (E.G., CUSTODIAN HAS MOVED) 12. ( ) DOCUMENTATIClf OF INFORMATION (FEDERAL TAX OFFSET) A. ( ) VERIFICATION OF PROVISION OF SSN B. ( ) VERIFICATION AND PKWISla. OF SUPPORT ORDER AND AllY K>DIFlCATIONS C. VERIFICATION OF ARREARS AND PROVISION OF CALCULATIClfS 13 . (X) OTHER: COMMENTS 5. ("q INCOME WITHOLDING 4. ( ) K>DIFlCATION OF EXISTING RESPONDING STATE ORDER (URESA) 6. (") COLLECTION OF ARREARS (URESA OR UEFJA) II. ACDlCMLEOOMENTS TO BE CC>>lPLETED BY RESPONDING AGENCY UPClf REQUEST ( ) REQUEST RECEIVED AND NO ADDITIONAL INFORMATION RBCESSAJlY TO ProCEBI) ( ) ADDITIONAL INFORMATION REEDED TO ~ (SEE REMARKS) REMARKS/RESPONSE (ADDITIClfAL INFORMATION NEEDED: ADDRESS CORRECTIONS, CONTACT PERSON, ACTION RESULTS, ETC.) A TRUE COpy FHOM pr:r'('R-<' 0 . ~ .,'__ \ "At '", ' 'r' ~1.:~r1. !':i';nd i.1~-~;J ""'" CASE BAS BEEN _ED FOR ACT'''' '" ''''''. -cr. ......... -. F1""n"~;;:.l1-iif:~:::_c.. '21 .Oc~~",,! C!::r=t (\7 Cc",~ ':) ~."(",, W CU~be;;",~;j ~:::,;,,:/ ,';CC.~lc~:f.!n o:::p,-r,;:; Ch,n,......, 1....;1d County SIGNATURE (RESPONDING AGENCY) .~ ", , . 'PHOMB'litllmU, (INCLUDE AREA CODE) .000t;lIJ elM< of Courts Cumbe7land C,:::m1"/ CCYn';';!:'lSion exp!r€~; First ~.~o~,d:,~'1'~ ,,~'1r\' ':''';' 20 J?d::.. DATE FORM FSA - 200 CHILD SUPPORT ENFORCEMENT ACDlOWLEDGEMENT PAGE 1A OF 2 OMB NO. 0970-0085 STATE OF FLORIDA DEPARTMENT OF REVENUE 1823 Business Park Boulevard, Daytona Beach, FL 32114 General Tax Administration Child Support Enforcement Property Tax Administration Administrative Services Information Services L. H. Fuchs Executive Director November 16, 1998 Pamela Bottorf 19 Putter Drive Palm Coast, FL 32164 Dear Ms. Bottorf, I am in receipt of your letter dated November 11, 1998. Your reasons for closing your child support case with the Florida Department of Revenue have been duly noted. Your letter along with the supporting documentation has been placed in your file. Sincerely, 'fQt~ Pat Clark Revenue Service Center Manager .9ug '10 05 04: 36p l<""'ss8.Burden 3862580030 IN THE CIRCUIT COURT, SEVENTH JUDICIAL CIRCUIT, IN AND FOR FLAGLER COUNTY, FLORIDA IN RE: The Marriage of CASE NO.: 96-752-CA PAMELA S. BOTTORF, nlk/a, PAMELA DENT, Petitioner, -0 ~":J )> -< -0 rn ;0 :z: <:> and ~ ~ ['.) c....;, RICHARD E. BOTTORF, JR., Respondent. / ORDER THIS CAUSE having come before the Court upon the issues of credits and arrearages pursuant to the Court's Order dated August 3, 2005, and the Court being otherwise fully advised in the premises, it is hereby ORDERED AND ADJUDGED that the Former Husband's current arrearage figure for child support is $32,229.39 and his arrearage for previously-ordered costs is $2,144.07 for a total amount of $34,373.46. A judgment is entered against the Former Husband in the amount of $34,373.46 for which let execution issue. DONE AND ORDERED in Chambers at Bunnell, Flagler Coun~,~~, this Q day ~ -- of CIRe(/, " . ' :L.<I:-'f.: ........ ";. t, __ ,2005. "" "..~..\l" .. a , ". c:r.. :!V ~ ... Q ",: ~. ~ , If. · . "'~ " I. : . ., ~ :." -' <- I, ... "..... ......... t" -- a,\ COUN".... _.:' \\"",... of cc: Leonard R. 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(I) po gg8888 (') f.IJ ~.~ ~';g p.o ~ QO ,......,.................................. ~ .... ~~~~~~ (1) l-J VlVlVlVlVlVl ~ ~ ~ ~ .~ .~ .~ ~ (/1 ~~($)($) ~ ~ N ~ ~ l,jj>-O !P ~ t .... >1 ~ ... e..~ lJ\ Bi ~ S a-. ~ ..... ~ ? Q ~% \c ;.... ~ ~ ~ ~ a-. ~ ..... ~ ~ .... .... ~ ... t ...-1 0'\ ...~ 0 ~ ~ a-. ~ ~ \Q ~ QO \J\ -1 (1) Q ~ 4 be e ~ ';!? a-. -1 QO ~ ~ ~ 't ~ ~ 0 ~ $' QO a-. ~ e. '\,.) U\ ~ ~ t..l 0'\ $ ~ ~ -J ..... . ~ \Q ;... ~ ~ '" ~ 0'\ QO \J\ ~ ~ ~ ~p.tn ~ 0 ';:3. 0 ~, o~e.. ~~tf) OQ ....0 'Ul (') ~.~g. g'Ul.:;t 0"0 l:f ~ oaa ~. tJQ~ (') ~. S'.o p:~ ~ ~ ~ t..J ,.... - - ... ... "-1 ... 0 ....... 6 QO a-.. ~ ,.... ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ i;:l ~ QO ~ Hug 30 05 04:38p P"'ss&Burden 3862580030 p.8 " ~. IN THE CIRCUIT COURT, SEVENTH JUDICIAL CIRCUIT, IN AND FOR FLAGLER COUNTY; FLORIDA CASE NO 96-752-CA PAMELA S. BOTTORF. Petitioner. v. RICHARD E. BOTTORF, JR., Respondent. I ORDER FOR ARREST TO ALL AND SINGULAR THE SHERIFFS OF THE STATE OF FLORIDA GREETINGS THIS is to command you, as you have heretofore been commanded, to take RICHARD E. BOTTORF. JR., if he is found in your County, and deliver him for transportation to the Flagler County Jail where he is to be incarcerated for a period of 90 days. as a consequence afms contempt in failing to comply with the previous Order of this Court entered herein on November 3, 1999, a copy of which is attached hereto. The Respondent may purge himself of the said contempt and may be released from custody by payment to the Clerk of the Court of Flagler County, Child Support Division, the sum of $2,000.00 together with $5,25, Clerk's cost, and prior to release shall also pay $25.00, Sheriffs costs. The Respondent shall further pay prior to release, any costs accrued by the Flagler County Sheriff or any County Sheriffs office for transportation or otherwise as a result of this order. DONE AND ORDERED in chambers at Flagler County jJ>urthouse, Bunnell. Flagler County,FJoridatbis_ 16" day of February, 2000. ~U~ / CIRCUIT JUDGE cc: Richard E. Bottorf, Jr., 405 Wren Court Mechanicsburg, PA 17055 Pamela Bottorf. 19 Putter Drive, Palm Coast, Fl32164 1 Rug 30 05 04:38p P'")ss&Burden 3862580030 p.s '" . ~ " / / l n-~ 11ffi C.LRCJIT COU1\.1') Sb VbNIH JUDICIAL CIRCUIT, IN' AND FOR FLAGLER COUNTY, FLORIDA ,/ ,// ,,/ ,/~ CASE NO.: 96-752-CA PAMELA S. BOTTORF, Petitioner, and RICHARD E. BOTTORF, JR., Respondent. I ORDER FOR CONTEMPT THIS CAUSE came before the Court a motion for contempt tiled by the Petitioner and motion for continuance filed by the Respondent.. The Petitioner was present for the hearing; the Respondent was absent, however, he was represented. by Jerome Rotenberg, Esq. The Court having reviewed th.e motions and heard arguments and evidence of the parties, finds that the Respondent has not paid the court ordered child support. Additionally, this Court finds that the Respondent possesses the ability to pay the amount imposed by the Court, however, he has willfully disregarded this Court's order. THEREFORE, it is hereby ORDERED and ADJUDGED that 1, The motion for continuance is DENIED. 2. Respondent, RICHARD E. BOTTORF) JR. is in contempt of this Court's order to pay child support. He is in arrears in the amount of $17,483.38 as of October 21, 1999. 3. Respondent is to serve -!t2. days in The Flagler County Inmate Facility; such sentence is suspended providing the Respondent purges himself by paying $2,000,00 within 20 days oftrus order to the Clerk of Court, Post Office Box 787, Bmmell, FL 32110. Said purge shall included the Clerk's fee of 4% or a flat fee of $5.25 which ever is less. Therefore, Respondent shall pay a total of $2,005.25, 4. The purge payment shall be made. pursuant to this Order, by cash, money order, cashiers or certified check. The monies paid in the process of purging may be collected by the Flagler County Sheriff on behalf of the Clerk of the Circuit Court, ~ug 30 05 04:38p p..,sstoBurden 3862580030 p. 10 ~ t. :'~ ~:b::1n ~a ~:,~.:;:..h ::. :~~~ ~~:) ~~ "; ~~~::L~::~j.::~(;d ~~ tl"l(; "C("l}:~.,:~U~, r...:..h~~lv{lJ 1-: i', l~i01~ 'r''rlit~ilil two days' of receipt. 5. A judgment is entered against the Respondent in the amount of $17,483.3 8 for which let execution enter. DONE and qRD~~n Chambers, at the Flagler County Courthouse, in Bunnell. Flagler County, Florida this ~ day of November, 1999. ~~ /KimC. Hammond CIRCUIT JUDGE cc: Pamela Bottorf 19 Putter Drive Palm CO,ast, FL 3~.l64 Richard E. Bottorf: Jr. 405 Wren Court Mechanicsburg, PA 17055 " ~ug 30 05 04:39p , D"'lss@..Burden 3862580030 p. 11 Social Security Administration Retirement, Survivors and Disability Insurance "':" ," .... 1 'I .\iJI.H";~ vi ~,\,,''y'~i'u Office of Central Operations 1.500 \Voodlawn Drive Baltimore, Maryland 21241.1500 Date: October 9, 2000 Claim Number: 168-48.3931HCl PAMELA S BOTTORF ~"'OR LINDSAY MAE BOTTORF 19 PUTTER DR PALM COAST; FL 32164,.740-1 1,.11.. .1.111.11.111111'11111I1, 1"11111,, I" lUll II.' HI ,1..1 LINDSAY M BOTTORF is entitled t:o monthly child's benefits beginning March 1999. We have chosen you to be her representative payee. Therefore. you will re<:eive her checks and use the money for her needs. What We Will Pay And When . You will receive $4)172.25 around October 15) 2000. . This is the money LINDSAY is due for March 1999 through September 2000. - . LINDSAY MBO'I'TORF's next payment of $291.00. which is for Oerober 2000, will be received on or about the third Wednesday of November 2000. . After that you will receive $291.00 on or about the third Wednesday of each month. . These and any future payments will go to the financial institution )'01.1 selected. Please let us know if you change your mailing addreS5, so we can send you letters directly. . Later in this letter, we will show you how we figured these amounts. The day we make payments OIl this record is based 011 RICHARD E BOTTORF JR's date of birth. Enclosure(s): Pub 05-10076 Pub 05-10077 Pub 05-10075 c '<f.,"~-':"'~""~ \. ,\, ....::,:~..;:c'\>f\,:.~:I.:CJJl:f1EBY CERTIFY this to be a true __ . d~-:~ ciJ:~"f4 ' #;orrect copy of the origInal ~ t!/J~ "t.r~di~hisqffice, FJiJ ~. r;..; da1ed tf$s Day of . See Ne~Te. : <( " j ~, .."'....,. .' /flt..'"'& () '-LJ GAIL WADSWORTH "("f/,,...........,...';,.J..,.;" CLERK Jl;~ COURT · ~,-... '~~~ - (2i ~ \ cR :,;0 -- aM- }) O,C \\'..",'\,"..,; 3 Yahoo! Mail- pambcic@yahoo.com Page 1 of ] YAHoOf0 MAIL Print - Close Window Date: Wed, 29 Jun 200510:19:45 -0700 (PDT) From: Bbottorf@netscape,com To: PAMBCIC@YAHOO.COM Subject: PLANS I WILL EMAIL YOU THIS EVENING WITH ALL MY PLANS. IT HAS BEEN HARD TO LINE EVERYTHING UP SO QUICKLY. I DID NOT REALIZE HOW COMPLICATED I VE BECOME. RENTS ARE DUE ON LAST DAY OF MONTH, CANT TRUST JUST ANYBODY TO MAKE THE DEPOSITS A LOT OF IT IS CASH, I DO KNOW THE LATEST I WILL BE LEAVING IS THURS. MIDNIGHT. IT TAKES ME 14 HRS TO HIT ORLANDO. I WILL GIVE YOU EXACTS TONIGHT. HAVE ABOUT A DOZEN CALLS AND 1 VISIT ON THE PUPPY'S. ALLOT OF FOLKS WANT THEM BUT DON'T HAVE CASH, HAVEN'T SEEN A STAR WARS MOVIE IN YEARS, HOPE ITS GOOD ILL SEE THIS ONE CALL WHEN EVER I'LL PIC-UP OR E-MAIL ME AND I'LL CALL YOU. THANKS AGAIN PAM, RIC Netscape. Just the Net You Need. http://us.f570.mail.yahoo.com/ym/ShowLetter?box=Inbox&MsgId=9240 _ 243965 _2802_... 10/23/2006 " -' IN RE: The Marriage of PAMELA S. BOTTORF, n/kIa PAMELA DENT, Petitioner, IN THE CIRCUIT COURT, SEVENTH JUDICIAL CIRCUIT, IN AND FOR FLAGLER COUNTY, FLORIDA CASE NO.: 96-752-CA and r....,.. -'"' [< RICHARD E. BOTTORF, JR, Respondent. :':; ey" .."~.., :, ! " /" ',', ~ I 1 ANSWER QF RESPQN1>Em' TO ~0110N ~OR WRI1 OJ! NE EXEAT ~ FOft;~O~ ~ lWQTION TO OUAS\J WIW' COMES NOW Respondent, RICHARD E. BOTTORF, JR, and answers the allegations of the Petitioner's motion as follows: 1. Respondent denies that either the Final Judgment of Dissolution, or the prior Order of Arrest support issuance of the Writ. Respondent further states that although such a Writ is provided fOf in Section 61.11, Florida Statutes, such procedure is not to be used to force a party to post security to satisfY a judgment. Respondent further affirmatively states that the Writ should be Vacated in that it is not supported by sworn allegations as required by Section 68.02, Florida Statutes, that Petitioner bas fuiled to post a bond to secure Respondent's damages in the event of wrongful issuance, and that other less severe remedies are available to Petitioner which Petitioner has not exhausted. 2. Respondent states that the arrest order of February 16,2000, expired when it was unexecuted for over 5 years. Respondent further denies that the order itself was valid, I"-.) = = l:..,rt ~,jJ r'V .. 1'.:1 );> ~ ... ..... ./ in that it essentially wrongfully sentenced him for criminal contempt instead of civil contempt. Respondent further states that he has not removed himself and his property from the state, in that he bas at all material times herein been a resident of Pennsylvania and has not owned property in the state of Florida, all of which facts were well known to Petitioner. Respondent denies that he bas fraudulently conveyed his property, concealed his property or secreted himself so as to avoid arrest. 3, Respondent denies that he bas willfully fuiled to pay child support and that he owes $62,338,39, stating that as of September, 2000, he bas been on Social Security Disability, and that the Social Security Administration has made direct payment to Petitioner for the minor child in the form of a lump sum of approximately $10,000, and monthly payments in excess of$900 per month. Petitioner refused to allow such payments to be made through the Clerk of Court for credit herein because she did not want Respondent to know where she lived. 4. Respondent denies all the allegations of paragraph 4. 5. Respondent admits that he bas engaged in the rental business and owns rental property, but denies that he bas concealed himself. 6. Respondent was enticed into the State of Florida by Petitioner on the guise that he would be allowed to see his minor child, whom he bas not seen in 12 years. Petitioner engaged in this artifice solely for the purpose of having Respondent arrested and wrongfully detained by this court. 7. Respondent bas been forced to retain the undersigned attorney to represent him in this action and bas agreed to pay him a reasonable fee for his services. Petitioner should /' ~ . t/" 'r''o be required to pay these fees by virtue of her actions in bringing this groundless and vexatious action WHEREFORE~ Respondent demands that the Writ be Quashed~ that he be immediately released, or alternatively, that a reasonable bond be ordere<L that Petitioner be granted no relief and that she be ordered to pay his attorney fees. ~ Fla. Bar No.: 273112 630 N. Wild Olive Ave., Suite A Daytona Beach, Florida 32114 (386) 253-7865 Attorney for Respondent I HEREBY CERTIFY that a true and correct copy of the foregoing has been served by hand delivery on Petitioner's attorney, Leonard R Ross, Esquire, 434 N. Halifux Ave., Ste. 1, Daytona Beach, Florida 32118, this ~y of July, 2005. Da~~ Counsel for Respondent -- :~' 1 ~~:~ ~,,,~ ,~ 4. 7r~ fY" (': j!' ,'?l,~ "",,~ . (/'1, rl) :""'.) I HEREBY CERTIFY thi and correct copy of filed in this Off!{.~ Dated this Day of A 0 20 Crf./ GAIL WADSWORTH . . ~ERI< OF ~OUFff BY ~/d< ~, n- J' r' er- E:: p.; (~~ ; ......., .~'W' ,:;~> ( ,,~ " .... . . ~ Inst No:98014151 Date:0&/30/1998 SYD CROSBY, FLAGLER County By: 711.~ D.C. Time:12:5&:2 ~~~ 0620PAGE0426 IN THE CIRCUIT COURT, SEVENTH JUDICIAL CIRCUIT, IN AND FOR FLAGLER COUNTY, FLORIDA CASE NO.: 96-752-CA ;::~ .. CD eel ,_ r c= -:'1'''''' ";',~ PAMELA S. BOTTORF, Petitioner, rT) ~, I _. i~ C) f'\) :' I (0 . I f~p1 f -0 ,:3 r0 1 C..) 00 , .. . , and RICHARD E. BOTTORF, Respondent. FINAL JUDGMENT OF DISSOLUTION OF MARRIAGE THIS CAUSE having come on before this Court upon Petition of Wife and Answer thereto and the Stipulation of the Parties announced on the record at Final Hearing on May 21, 1998, and the Court being fully advised in the premises, it is hereby ORDERED AND ADJUDGED as follows: L JURISDICTION: This Court has absolute jurisdiction of the parties and the subject matter of this action. 2. DISSOLUTION OF MARRIAGE: The marriage between the Wife, PAMELA S. BOTTORF, and the Husband, RICHARD E. BOTTORF, is dissolved because it is irretrievably broken. 3. ISSUES PERTAINING TO THE MINOR CHILD: A. Sole and exclusive parental responsibility of the minor child, LINDSAY BOTTORF, date of birth November 24, 1990 is awarded to Petitioner, PAMELA S. BOTTORF subject to further order of this Court. B. The Court finds that it is in the best interest of the minor child that the Respondent, .' .. ~kt 0620PA6E0427 RICHARD E. BOTTORF, undergo a psychological evaluation by a psychologist mutually agreeable to the parties and the Court. Should the Court appointed psychologist deem it necessary, the Wife and the child will also meet with the psychologist. The Wife shall have the right to advise and consult with the psychologist prior to the time the psychologist provides any written reports to the Court and the parties. The entire costs of the evaluations shall be RICHARD E. BOTTORF'S sole responsibility. C. There shall be no communication between the Husband and the minor child until further order of the Court. Upon completion of the psychological evaluation or evaluations referenced above, the Court shall hold an expedited telephonic hearing to address the issue of telephonic communication between the Husband and the minor child, unless the parties enter into a written stipulation prior to that date. D. Both parties recognize and agree that each parent has a right to a private life; that the minor child should not be questioned about that private life; that the child has the right to be free from being present during the parents' personal battles; that the child has a right to be free from being used by either parent as a spy, a courier, or a bargaining chip; that neither parent shall disparage the other in the presence of the child in any way, shape or fonn. E. As and for on-going child support, RICHARD BOTTORF, shall pay the sum of four hundred twenty-six dollars and forty-eight cents ($426.48) along with the statutory fee, on the first of each and every month hereafter through the Clerk of the Courts, Post Office Box 787, Bunnell, Florida 32110. In addition, the Court establishes arrears in the sum of$8,953.78, representing the Respondent's child support obligation from the date of filing of the petition in the instant case. Said arrears are due instanter. The income deduction order entered on February 26, 1997 shall remain in full effect until further order of this Court. .' " ~~~ 0620PAGE0428 indirectly, whether in person, by telephone, in writing, or by computer, Any relief granted by this injunction shall be effective until further Court Order. Pursuant to Section 901.15 (6) and (7), an officer may arrest Respondent without a warrant for violating this injunction when the officer has probable cause to believe Respondent has (1) knowingly committed and act in violation of this injunction which creates a threat of imminent danger to the Petitioner or household members, over the objection of Petitioner, if necessary; OR (2) committed an act of domestic violence as defined in section 741.28, Florida Statutes, and the officer reasonably believes that there is danger of violence unless the person alleged to have committed the domestic violence is arrested without delay. This paragraph does not limit or expand the officer's arrest authority conferred by any other provision oflaw. (See Section 910.15, Florida Statutes, generally.) Respondent shall be taken to the next first appearance if arrested for a crime and thereafter may be admitted to bail in accordance with the provisions of chapter 903, Florida Statutes and the applicable rules of criminal procedure pending hearing or trial. 5. ATTORNEY'S FEES: Pursuant to the temporary order entered by the Court on February 26, 1997, the Court awarded temporary attorney's fees in the sum of$750.00 and orders the Respondent, RICHARD E. BOTTORF, to pay said amount instanter to the Wife's counsel, Leonard R. Ross, Esquire, 434 N. Halifax Avenue, Daytona Beach, Florida 32118. The Court reserves ruling with respect to additional attorney's fees on behalf of the Wife. 6.. RESERVATION OF JURISDICTION: The Court specifically reserves jurisdiction as to the dissolution of marriage granted in this judgment, the issues of child custody, visitation and support and the enforcement thereof. The Court will reserve final ruling with respect the issues pertaining to custody, visitation, support, attorney's fees and costs. The Court . .. ~~t 0620PAGE0429 F. The Wife has agreed to terminate her action in Cumberland County, Pennsylvania with respect to child support and all child support obligations of the Husband, RICHARD E. BOTTORF, shall be paid through the Clerk of the Court, Flagler County. G. The parties shall each be obligated for fifty (50%) of all medical bills not covered by insurance on behalf of the minor child. The current medical expenses are established at eight hundred seventy-two dollars and fifty-seven cents ($872.57). RICHARD E. BOTTORF shall pay to PAMELA BOTTORF the sum of four hundred thirty-six dollars and twenty-eight cents ($436.28). H. RICHARD E. BOTTORF shall maintain his present life insurance policy with a minimum value of $100,000.00, naming the minor child as beneficiary, in effect until such time as the minor child reaches the age of majority, to secure his child support obligations. 4. INJUNCTION: The injunction dated August 30, 1996 shall remain in effect whereby Respondent/Husband, RICHARD E. BOTTORF, is ordered not to commit any act of violence, abuse, threat, or harassment, at any time or any place whatsoever, including, but not limited to, assault, battery, sexual battery, stalking, aggravated stalking, or any criminal offense resulting in physical injury or death to Petitioner/Wife, the minor child, or any member of Petitioner's immediate family. Respondent is further ordered not to cause any other person to commit any act of violence, threat, or harassment upon the Petitioner and the minor child. Respondent/Husband shall not go onto the residential premises of Petitioner /Wife, living separately located at 19 Putter Drive, Palm Coast, Florida or wherever Petitioner/Wife may live in the State of Florida. Respondent/Husband shall not go onto Petitioner/Wife's place of employment or wherever Petitioner may be employed or attend school in the State of Florida. Respondent/Husband shall not contact the PetitionerlWife or the minor child, directly or .' \ .. ~~~ 0620PAGE0430 indirectly, whether in person, by telephone, in writing, or by computer. Any relief granted by this injunction shall be effective until further Court Order. Pursuant to Section 901.15 (6) and (7), an officer may arrest Respondent without a warrant for violating this injunction when the officer has probable cause to believe Respondent has (1) knowingly committed and act in violation of this injunction which creates a threat of imminent danger to the Petitioner or household members, over the objection of Petitioner, if necessary; OR (2) committed an act of domestic violence as defined in section 741.28, Florida Statutes, and the officer reasonably believes that there is danger of violence unless the person alleged to have committed the domestic violence is arrested without delay. This paragraph does not limit or expand the officer's arrest authority conferred by any other provision oflaw. (See Section 910.15, Florida Statutes, generally.) Respondent shall be taken to the next first appearance if arrested for a crime and thereafter may be admitted to bail in accordance with the provisions of chapter 903, Florida Statutes and the applicable rules of criminal procedure pending hearing or trial. 5. ATTORNEY'S FEES: Pursuant to the temporary order entered by the Court on February 26, 1997, the Court awarded temporary attorney's fees in the sum of$750.00 and orders the Respondent, RICHARD E. BOTTORF, to pay said amount instanter to the Wife's counsel, Leonard R. Ross, Esquire, 434 N. Halifax Avenue, Daytona Beach, Florida 32118. The Court reserves ruling with respect to additional attorney's fees on behalf of the Wife. 6.. RESERVATION OF JURISDICTION: The Court specifically reserves jurisdiction as to the dissolution of marriage granted in this judgment, the issues of child custody, visitation and support and the enforcement thereof. The Court will reserve final ruling with respect the issues pertaining to custody, visitation, support, attorney's fees and costs. The Court ...: ," " .: ,\ . ~&~ 0620PAGE0431 order of February 26, 1997 shall remain in full force and effect. Further, both parties are ordered to take whatever action necessary to, and conduct themselves in any manner conducive with, carrying out the intent and purpose of this Judgment. ~\ DONE AND ORDERED in Chambers, at Bunnell, Flagler County, Florida this ~q day of ~. cc: Leonard R. Ross, Esquire David Fuller, Esquire be a true ERE6'< CERilf'< \~~S ~~e origi\'\al I Hd correct cor;N 'JleJC a\'\ \ otiice, 'iled i\'\ t~ ~oa~ 0\ oated t\'l\S~! WAOSWOPtiH vrd.", ~GAIL COIJRi A. 0, 20~f \ CUI' ,C, 6'< ~i .' gaberdiel and Warren COURT REPORTERS , - ,. :...- IN THE CIRCUIT COURT, SEVENTH JUDICIAL CIRCUIT, IN AND FOR FLAGLER COUNTY, FLORIDA CASE NO: -Q ("1 " :t:>- ,'::;) 96C75~C~ N c '-' \ en ftu~ (r;' , ~-} . , ( .', _..",~ , I . ~ IN RE: THE MARRIAGE OF -0 :::':"3 PAMELA S. BOTTORF, 1'.J N o Petitioner/Wife, and RICHARD E. BOTTORF, i Respondent/Husband. -------------------------------- / j ,~ --. STATE OF FLORIDA COUNTY OF FLAGLER Proceedings before the Honorable Kim Hammond, Judge of the Circuit Court Judge, as cause in this matter came to be heard on the 21st day of May, 1998, before Sloane M. Vostrejs, Court Reporter and a Notary Public in the State of Florida at Large. Patricia A. Gaberdiel Mary F. Warren 444 Seabreeze Boulevard, Suite 735 Daytona Beach, Florida 32118 Phone 904-255-1263 Fax 904-255-9387 P.O. Box 263154 Daytona Beach, FL 32126-3154 ...',... '; , 2 " 1 APPEARANCES: 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 LEONARD R. ROSS, ESQUIRE 434 North Halifax Avenue Suite 1 Daytona Beach, FL 32118 Attorney for Petitioner/Wife DAVID D. FULLER, ESQUIRE Whited, Davis & Fuller 220 South Ridgewood Avenue Suite 210 Daytona Beach, FL 32114 Attorney for Respondent/Husband .' 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 3 PRO C E E DIN G S 1:00 p.m. May 21, 1998 This is a hearing in the THE COURT: matter of Bottorf, 96-752. Do we have an announcement? MR. ROSS: Yes, Your Honor. I believe we've reached a stipulation. As I understand it, the stipulation that we'll enter into is, number one, that the parties both stipulate to the state of Florida having jurisdiction over the subject matter in addition to the personal jurisdiction in this matter; that, two, there will be a dissolution of marriage granted in the matter, and they'll specify the requirements with respect to that; that, three, the temporary order of the Court is fully adopted. That order of February 26th, 1997 is adopted with the following additions. And that is, that one sole and exclusive parental responsibility of the minor child, Lindsey Bottorf, will be awarded to Pamela Bottorf. The father will have to have psychological evaluations. The father and mother, if the psychologist believes it's necessary as well as the child, by the 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 psychologist that the Court appoints. That prior to there being any communication with the child telephonically, there would have to be the evaluations by the father. And the father will bear the expense of all the evaluations with respect to any communication concerning the -- any psychological evaluations. If we can agree following the evaluations that there should be telephonic communication started, then we would initially stipulate to that right away. If we couldn't agree, the psychologist will make a recommendation and we'll have an expedited hearing with respect to that. MR. FULLER: Which can be handled telephonically, which would not require him to corne back down. Now, one thing that I want to interject right here while we're doing this is we agreed that this would be a bifurcated process; that you would enter a final judgment resolving the marriage as a final judgment and you would reserve on the issues of custody, support, those issues that are addressed in the temporary order. And that those -- the child support that 5 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 was provided in that temporary order would continue until further order of the Court. And that the visitation provisions in that -- or the custody/visitation provisions of that agreement that Lenny has just told you about, would remain in effect until further order of the Court with the exception that visitation would be addressed now just as Lenny said, if Mr. Bottorf would submit himself to an evaluation by the psychologist that has been appointed by you or that you could appoint -- THE COURT: Or that you can agree upon, either one. MR. FULLER: Well, you had suggested John Welsh. THE COURT: Those are the only two that I can think of. There may be more in Palm Coast, but those are the two -- MR. FULLER: I don1t know him, but I don't see any reason to believe he's not acceptable. And I don't think he would have any objection to him. MR. ROSS: Correct. MR. FULLER: Okay. And that the telephonic communication, essentially all 6 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 communications, would be contingent upon Mr. Bottorf initiating that process, counseling with the counselor and the counselor reporting to the Court. Any objection with that? MR. ROSS: As to... MR. FULLER: As to the suitability of initiating contact. MR. ROSS: Correct. And then we would have a hearing unless we agree. MR. FULLER: Right. THE COURT: And do I understand that the parties should not, in any way, alienate the affections of the child; that there should be no discussion with the child about the problems of the relationship or either parent discussing the other parentis life or lifestyle; that we're going to keep the child out of the "caught in the middle of that" kind of scenario? As I understand it, the parties have expressed a genuine desire to know and associate and enjoy the love, contact, affection of the child, which has to be earned. But the purpose of that is not to, in any way, use the child or to interfere with each other's life as you go on making your own life. 7 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MR. FULLER: Okay. No disparagement in any way, shape or form -- THE COURT: And this would apply to both parents. MR. FULLER: - - to or in the presence of the child. MR. ROSS: Correct. THE COURT: No pumping the child for information about the other side when a relationship becomes established, that sort of thing. MR. FULLER: And that the injunction for protection that you entered, I guess, that MR. ROSS: Will remain in full force. MR. FULLER: And all the standard language that's in that will remain in effect. Essentially what you've done then is continue the effectiveness of the temporary order pending further hearing reserving jurisdiction over those issues that are addressed in that order. THE COURT: And if either party believes there's been a change in circumstances or if the other party is being unreasonable in some fashion, then the matters will be called up to the Court for the Court's consideration. 8 1 ) 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MR. FULLER: THE COURT: to address those. That's correct. And I'll reserve jurisdiction MR. ROSS: Mr. Bottorf, I understand, will stipulate to arrearage at this point under the temporary order of $8,953.78. And in addition to that, he will begin immediately to pay the ongoing support through the Clerk of the Court under the temporary order, which is 426.48 along with the statutory fee. MR. FULLER: Now, that is one thing that is going to need to come through the courts in pennsylvania because they've assumed jurisdiction over him. And now we have a situation where both Courts have jurisdiction over him. If he doesn't account to them for the money, he's going to face their contempt powers. So if you don't have a problem with it -- unless that action up there can be terminated, it's going to need to go through that -- what's that commonwealth up there? MR. BOTTORF: Cumberland County Court. MR. ROSS: You know what, we'll terminate that if we can just have it sent through the Clerk of the Courts here. And Mr. Bottorf would 9 1 '\ " 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 begin paying that immediately; is that right? MR. FULLER: That's fine, he says. So if we can terminate the proceedings in the state of Pennsylvania, Ms. Bottorf will cause that to be done, he will make his payments through the Clerk of the Court in Flagler County. MR. ROSS: The other issue, I guess as I understand it, number one, we'll reserve the issue as to the attorney's fees for a subsequent hearing -- MR. FULLER: We'll reserve all the other issues there. MR. ROSS: There are medical expenses that were -- obviously, there's already a prior order as far as attorney's fees that stands, but as far as any subsequent attorney's fees, that will be reserved. That's in the temporary order right. MR. FULLER: Well, the temporary order remains in effect MR. ROSS: Mr. Bottorf will purchase a life insurance policy, term-life insurance. He represented he had some already, right, for the benefit to secure the child support? And does that have $100,000 face value? 10 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MR. BOTTORF: I have $1.350 million worth She is well taken care of in of life insurance. my will. MR. ROSS: And the child will be named the beneficiary of that, right? MR. FULLER: To the extent of the child's - - THE COURT: The child is six? MR. FULLER: Right. MR. ROSS: Seven now. THE COURT: So 11 years, which is not very long, this will be in the child's life. Here we have this matter to deal with and we have the obligation to support the child and love the child and care for the child, and we're responsible to enjoy the association with the child. And so, you know, this situation is one that we need to address very soon and put things in order and try to do the best for the child because the child is going to need both of you. Maybe daddy isn't needed around as much right now, but daddy may be able to do things down the road to help the child in education, to help the child know that she is loved and cared for because it seems to me, and it's been my 11 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 experience, that a child needs at least two parents and, in many occasions, grandparents if they're available to help the child develop. And so we don't have a lot of time to deal with that. We've got 11 years to get this child into adulthood. And by then, she'll probably want to go college and then there's probably room for helping this child when that happens. So we need to be realistic about that and remember the child is not a potted plant and is not just something that we order around. It may suit ourselves, but the child has feelings and thoughts. And if the child is hurt or the child is put in fear or the child is apprehensive or distressful or any of all those negative things that happen to children, then children have a way of letting us know that. And one way they do that is to act out. they're uncooperative. And so you need to be prepared for that and you need to remember that the child is going to have things that the child is going to want They're distressful, to do and needs to do and you need to cooperate, both of you, with that child's life. She may 12 1 " I 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 want to go to a camp. She may want to go out on a date, maybe. She may not be on time to make a call or do something that you want done and that's the nature of children, especially as they get more adultlike. So it takes a little, if not a lot, of wisdom to rear a child. And I think you both need to be especially thoughtful about that and understanding about that. MR. ROSS: I think Mr. Bottorf is going to stipulate to pay one half of the medical expenses. We have all the bills there. The total amount is 872.57, which includes the prior amount which we addressed at the mediation, which was 747.02. But there's only been an additional, obviously, 130. So those are all the bills. Will you stipulate to paying half of that, sir? MR. BOTTORF: Yes. MR. ROSS: And that amount is 872.57. So it's one half of that amount. THE COURT: Let me inquire concerning the residence and the marriage being broken. If you would, Madam Clerk, swear Mr. Bottorf -- or both parties, please. 13 1 ) 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 (The witnesses were sworn by the Judge.) THE COURT: Ms. Bottorf, is it Pamela "S"? MS. BOTTORF: It's Pamela Sue. THE COURT: You're the petitioner in this matter and you've alleged that you've been a resident of the state of Florida for six months before the filing? MS. BOTTORF: Yes, sir. THE COURT: And how long were you a resident before you filed for dissolution? MS. BOTTORF: Six months. THE COURT: You were no more than six months? MS. BOTTORF: A few days over six months. THE COURT: Okay. And you allege that the marriage is broken? MS. BOTTORF: Yes. THE COURT: Can you tell me why you believe that to be true without going into a lot of detail? MS. BOTTORF: The marriage is irretrievably broken because of Richard's abuse. THE COURT: Okay. You don't get along? MS. BOTTORF: He's abusive. THE COURT: Okay. Do I presume from that 14 1 ) 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 that you object to the way the relationship was going, you felt uncomfortable about the relationship, you wished no longer to be married and the love went out of the relationship? MS. BOTTORF: Yes, sir, that's correct. In addition, he has threatened our lives. THE COURT: Okay. And you wish for me to grant the dissolution of marriage? MS. BOTTORF: Yes, sir, I do. THE COURT: Okay. I don't know how much of that he wishes to concede, but I think perhaps he agrees that the marriage is beyond repair; is that correct? MR. BOTTORF: Yes, sir. THE COURT: Okay. Would you submit to me a proposed final judgment reserving those matters that have been indicated? MR. ROSS: Yes, Your Honor. THE COURT: And understand that the parties -- and you may even include the language, encourage to be reasonable in dealing with the child and the child's relationship to themselves and each other, and the cautionary language about the behavior with the child. Ultimately, it's usually -- if parents are 15 1 \ I 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 not unfit for some serious reason, reasonable parents, loving parents are needed by this child. And there's only on extreme situations where conduct creates an unhealthy atmosphere that the custody is denied so-to-speak. You need to prove to win the child over. That isn't always easy and maybe sometimes adults don't know how to do that, but you need to be patient and cautious and considerate and consistent and reasonable in your dealings with each other over the child and in dealing with the child. Hysterics, anger, venom, uncontrolled frustration is not going to do anything but create a nightmare situation for the child. She doesn't need that and you folks don't need that. You have to build for the long run and you have 11 years to see to this child. And whether you accomplish that in 11 years or not, will depend on whether your child is loving and will enjoy a relationship with you for the rest of your life or not. And I hope you do that and I hope you are consistent and patient and responsible because it will mean a great deal, I think, down the road, okay? Let's see what we can do. 16 Submit that to my consideration and provide opposing counsel with a copy and then I will entertain it. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MR. ROSS: Can we take testimony on residency right now, Judge? THE COURT: I thought we had satisfied that, but maybe we haven't. Maybe you have a corroborating residence MR. FULLER: Does she have a voter's card or a driver's license showing six months? That's all you have to do. Yeah, we've got the voter's That's fine. Thank you very much. (The proceedings concluded at 3:54 p.m.) MR. ROSS: card. MR. FULLER: six months? MR. ROSS: MR. FULLER: MR. ROSS: THE COURT: the clerk? MR. ROSS: THE COURT: Does that have a period of It does. Right here. I'll stipulate. Okay. We'll stipulate to that. You will file that copy with i 1 ) 2 3 4 5 6 7 8 9 10 11 12 ) 13 14 15 16 17 18 19 20 21 22 23 24 25 17 AFFIDAVIT OF REPORTER STATE OF FLORIDA COUNTY OF VOLUSIA I, SLOANE M. VOSTREJS, Court Reporter and a Notary Public, certify that I was authorized to and did stenographically report the proceedings of May 21, 1998; and that the transcript is a true and complete record of my stenographic record of my stenographic notes. I FURTHER CERTIFY that I am not a relative, employee, attorney, or counsel of any of the parties, nor am I a relative or employee of any of the parties' attorney or counsel connected with the action, nor am I financially interested in the action. DATED this 5th day of June, 1998. ~7U~J1~~it-Reporter I HER~i\l e~~tlpty this to be a true and correct copy of the original filed in this off~e. j fl. /1"_ d. ~ Dated this /J ~ay of~' A. D. 20 0& GAIL WA LERK OF BY :2 ." IN THE CIRCUIT COURT, SEVENTH JUDICIAL CIRCUIT, IN AND FOR FLAGLER COUNTY, FLORIDA CASE NO 96-752-CA PAMELA S. BOTTORF, Petitioner, v. RICHARD E. BOTTORF, JR., Respondent. / ORDER FOR ARREST TO ALL AND SINGULAR THE SHERIFFS OF THE STATE OF FLORIDA GREETINGS THIS is to command you, as you have heretofore been commanded, to take RICHARD E. BOTTORF, JR., if he is found in your County, and deliver him for transportation to the Flagler County Jail where he is to be incarcerated for a period of 90 days, as a consequence of his contempt in failing to comply with the previous Order of this Court entered herein on November 3, 1999, a copy of which is attached hereto. The Respondent may purge himself of the said contempt and may be released from custody by payment to the Clerk of the Court of Flagler County, Child Support Division, the sum of $2,000.00 together with $5.25, Clerk's cost, and prior to release shall also pay $25.00, Sheriff's costs. The Respondent shall further pay prior to release, any costs accrued by the Flagler County Sheriff or any County Sheriff s office for transportation or otherwise as a result of this order. DONE AND ORDERED in chambers at Flagler County C urthouse, Bunnell, Flagler County, Florida this_ 16111 day of February, 2000. CIRCUIT JUDGE cc: Richard E. Bottorf, Jr., 405 Wren Court Mechanicsburg, PA 17055 Pamela Bottorf, 19 Putter Drive, Palm Coast, Fl32164 1 _"__'M,..~,.,,~.,~____.~__"~'-'_'_"--"'" .. " ,/ .- / , .. L:-~ 11lli ClRCJIT COU1U', ShV,bNIH JUDICIAL CmCDIT, IN' AND FOR FLAGLER COUNTY, FLORIDA I l / ,./ " I CASE NO.: 96-752-CA PAMELA S. BOTTORF, Petitioner, and RICHARD E. BOTTORF, JR., Respondent. I ORDER FOR CONTEMPT TIDS CAUSE came before the Court a motion for contempt filed by the Petitioner and motion for continuance filed by the Respondent.. The Petitioner was present for the hearing; the Respondent was absent, however, he was represented by Jerome Rotenberg, Esq. The Court having reviewed th.e motions and heard arguments and evidence of the parties, finds that the Respondent has not paid the court ordered child support. Additionally, this Court finds that the Respondent possesses the ability to pay the amount imposed by the Court, however. he has willfully disregarded this Court's order. THEREFORE, it is hereby ORDERED and ADJUDGED that 1. The motion for continuance is DENIED. 2. Respondent. RICHARD E. BOTTORF. JR. is in contempt of this Court's order to pay child support. He is in arrears in the amount of $17,,483.38 as of October 21, 1999. 3. Respondent is to serve -!.t2 days in The Flagler County Inmate Facility; such sentence is suspended providing the Respondent purges himself by paying $2.000.00 within 20 days of this order to the Clerk of Court, Post Office Box 781, Bunnell, FL 32110. Said purge shall included the Clerk's fee of 4% or a flat fee of $5.25 which ever is less. Therefore, Respondent shall pay a total of $2,005.25. 4. The purge payment shall be made. pursuant to this Order, by cash, money order, cashiers or certified check. The monies paid in the process of purging may be collected by the Flagler County Sheriff on behalf of the Clerk of the Circuit Court, ';~ ,-.-ro.::J ,. '} 1:''l.~ ~3h:.~~1 ~!1 :.~.:::..ll C~~~~~:~.) ~~ ..: ~~~:~,.~:~~1.::~c:\1 ~..: tl'l\..: r;(:i1:.::~~ti~. D..~12.~~\..a'L31~,i'. ::::':0~~ 'rvit~ilil two days' of receipt. 5. Ajudgment is entered against the Respondent in the amount of$17,483.38 for which let execution enter. DONE and qRD~~.n Chambers, at the Flagler County Courthouse, in Bunnell, Flagler County, Florida this ~ day of November, 1999. ~ ~ /Kim C. Hammond CIRCUIT JUDGE cc: Pamela Bottorf 19 Putter Drive Palm CQ,ast, FL 3~.164 Richard E. Bottorf, Jr. 405 Wren Court Mechanicsburg, P A 17055 " IN THE CIRCUIT COURT, SEVENTH JUDICIAL CIRCUIT, IN AND FOR FLAGLER COUNTY, FLORIDA CASE NO.: 96-752-CA and "\J1 (~., )> -< "1lJ rT1 ~ Z o CD PAMELA S. BOTTORF, Petitioner, -;PO f'it..- _, ''71 ,"" '.:: <;:; ['';, ~~J :~<.. Z , i ~:::) f--> -...J (';) RICHARD E. BOTTORF, JR., Respondent. u :3 ~:~J:} ("'"',> c :;:j r:-; Z <'::. c> -1 : '~n ORDER v ~ N -L: ,--- " ,...j ./ r:1 / r---\ _.~..~ "', -'1 THIS CAUSE came before the Court a motion for contempt. The Court having reviewed the motion and heard arguments and evidence of the parties, finds that Respondent, RICHARD E. BOTTORF, JR., is not in CONTEMPT at this time. Respondent swore under penalty of petjury that he is disable, and has been since July of1997. He further represents that he has applied for disability payment and payment for the minor child is forthcoming. Nonetheless, Petitioner, PAMELA BOTTORF, argues that Respondent is not disable, however, she cannot present any admissible evidence to support her contentions at this time. THEREFORE, it is hereby ORDERED and ADJUDGED that cc: Pamela Bottorf Richard E. Bottorf, Jr. ..~~ . .~~ e. ...A~_ , ~~,......... ,~~~ '\ If" ('OUN1',~ ~.....~ CUlT Co C;\~"'"',''' 01> ,j" .' \)w, CUI'. r /r~1j9~;... . -.- . ,.,: : A. D. 20 ()I; GAIL WADSWOR ~>'" ~.. ;J/:/ t::IfJLERK Of!l/.~T COUR ,~-? .,'.". ,..,~,... 'r"') BY W~ 7 _ ',,'-UIf!\1 1'1 , D.C. :, f~"": I HEREBY CERTIFY this to be a tr and correct copy of the origin filed in this ~. Dated this Day of " 11(' ' -. IN THE CIRCUIT COURT, SEVENTH JUDICIAL CIRCUIT, IN AND FOR FLAGLER COUNTY, FLORIDA CASE NO.: 96-752-CA PAMELA S. BOTTORF, Petitioner, and ... .. t..O -.] ......, 0 ......, ""'T1 r- r- - 1""'1 )> ['T't r- CD C?;.:J m r-;:o::CJ N fTloz Cj) ::V......, -i OO:!: ~::D gom :3 _co . ..... 1 ::; ;::J -n " .... -< -i ......, . - \~ ~.~ ~ .1 Court upon the-Petitioner' s ..'. )00--< ... m '" z o RICHARD E. BOTTORF, Respondent. / ORDER THIS CAUSE having come before this Motion for Temporary Child Custody, Child Support, Attorney's fees and Costs, and the Court having entertained testimony, argument of counsel and being fully advised in the premises, it is hereby ORDERED AND ADJUDGED: 1. Sole and exclusive parental responsibility of the minor child, LINDSAY BOTTORF, date of birth November 24, 1990 is awarded to Petitioner, PAMELA S. BOTTORF. The Court has examined the psychological report and testimony of Dr. Susan F. Morey, Ph.D., and, as such finds that it is in the best interest of the minor child that there be no visitation with the Respondent, RICHARD E. BOTTORF, subject to further order of this Court. 2. As and for child support, RICHARD BOTTORF, shall pay the sUm of $426.48 along with the statutory fee, on the first of each and every month hereafter through the Clerk of the Courts, Post Office Box 787, Bunnell, Florida 32110. In addition, the Court establishes arrears in the sum of $2,130.10, representing the Respondent's child support obligation from the date of filing of the petition in the instant case. Said arrears are due instanter. , ,.. ~ Contemporaneous to this Court order, the Court enters an income deduction order against the Respondent. 3. The Court awards temporary attorney's fees in the sum of $750.00 and orders the Respondent, RICHARD E. BOTTORF, to pay said amount instanter to the Wife's~counsel, Leonard R. Ross, Esquire, 434 N. Halifax Avenue, Daytona Beach, Florida 32118. ~~(d(D ~ l ceq~ cc: Leonard R. Ross, Esquire Richard E. Bottorf I HEREBY CERTIFY this to be .8. true and correct copy of the original filed in this office. D{: r Dated this ~ ~ Day of (j ~ GAIL WADSWORTH A. O. 20 T LEAK OF CO BY IN THE CIRCUIT COURT, SEVENTH JUDICIAL CIRCUIT, IN AND FOR FLAGLER COUNTY, FLORIDA CASE NO.: 96-752-CA PAMELA S. BOTTORF Petitioner , and "!l':J ~--< IT! ;:;0 .. c.o --J C- :::0 ;:;c: .....',~..... r'r, C) ,'~ r-~' /~"? :';"'~ RICHARD BOTTORF, Respondent. o r- ::. NOTICE OF I / 11 ~, HEARI::erk of cauL ~; Family Law Division P.O. Box 787 Bunnell, Florida 32110 fll co ~ ~.:'.l TO: Honorable Kim C. Hammond Flagler County Courthouse P.O. Box 896 Bunnell, Florida 32110 ---- ,-::') Richard Bottorf, Esquire 405 Wren Court Mechanicsburg, PA 17055 PLEASE TAKE NOTICE that on the 11th day of February,1997, at 3:00 p.m. or soon thereafter as counsel can be heard, the undersigned will bring on to be heard, Petitioner, PAMELA S. BOTTORF'S Motion for Temporary Child Custody, Child Support, Attorney's Fees and Costs before the Honorable Kim C. Hammond in his chambers in the Flagler County Courthouse, 200 East Moody Boulevard, Bunnell, Florida. PLEASE GOVERN YOURSELF ACCORDINGLY. DATED this ~ day of January, 1997. I HEREBY CERTIFY that a true and correct foregoing has been provided by U.S. Mail to individuals on the aforementioned date. ~ ....,;il :) 1 I HEREBY CERTIFY this to and ,-..-. . PAMELA S. BOTTORF, Petitioner, IN THE CIRCUIT COURT, NINTH JUDICIAL CIRCUIT, IN AND FOR FLAGLER COUNTY, FLORIDA CASE NO.: 96-752-CA-u tro )>.--< OJ! rT1 ;:;:J .. CD -:J C- 1-' r- ::::J.:) .... ",. :;i:: o "1 and OJ RICHARD BOTTORF, Respondent. m.. - -~ .. ::n ::3 c: ....,." / (, 6 =::; :,~; c..v '1 C) N r-- rr: ):;-. MOTION FOR TEMPORARY CHILD CUSTODY. CHILD SUPPORT, ATTORNEY'S FEES AND COSTS COMES NOW the Petitioner, .PAMELA S. BOTTORF, by and through her undersigned counsel and files this Motion for Temporary Child Support, Attorney's Fees and Costs, and as grounds therefore would show: 1. Petitioner is a fit and proper person to have temporary and permanent primary residential responsibility of the minor child, LINDSAY BOTTORF, date of birth November 24, 1990. It is in the best interest of the minor child, LINDSAY BOTTORF, date of birth November 24, 1990 that the Petitioner, PAMELA S. BOTTORF be awarded temporary primary residential responsibility. Respondent is not a fit and proper person to have primary residential responsibility of the minor child. 2. Without temporary child support during the pendency of this action, the Petitioner will not be able to provide the basic necessities of life for the minor child, LINDSAY BOTTORF, date of birth November 24, 1990. 3. The Petitioner is also without adequate funds to pay the cost and attorney's fees necessary for proper representation in . ~ ~ this case. The Petitioner will seek an award of the same at or after trial and is not waiving her claim with respect thereto. WHEREFORE, the Petitioner seeks: 1. An award of temporary primary residential responsibility of the minor child, LINDSAY BOTTORF, date of birth November 24, 1990 to the Mother with a determination with respect to visitation. 2. An award to the Petitioner of temporary child support during the pendency of this cause. 3. An award to the Petitioner of reasonable attorney's fees for proper representation in this case. LEONARD R. ROSS, ESQUIRE 434 N. Halifax Avenue, Suite 1 Daytona Beach, Florida 32118 (904) 258-5069 Florida Bar No.: 332712 CERTIFICATE OF SERVICE I HEREBY CERTIFY that the original of the foregoing has been provided to Clerk of Courts, P.O. Box 787, Bunnell, Florida 32110 and that a true and correct copy of the foregoing has been provided by U.s. Mail and facsimile to Honorable Kim Hammond, Flagler County Courthouse, P.O. Box 896, Bunne 1, FL 32110 and R~ard Bottorf, 405 Wren Court, Mechanicsb g, PA 17055 this ~ day of January, 1997. If.. , r .,:, \ '.' ,Ml)NWEAlTH of PENNSYLVANIA J C,)unty of CUMBERLAND S5 I Robert P Ziegler, Recorder, do hereby C~rtify that the foregoing is. true and co~y as appears in II c- _ I J_ Vol. - - I R 7 'Page ...J I 10 .3 Wotn...~::z -1m,. ~ 4~~ ~ My Commission &pnI. ,. MondIv. January 2002 ~_'-~~-.J~~ .~.~~ ........ri., ....._...;.:. .'_n_'...... I.' ,..;.;.... ........_..... 36-117/- (iLe.;st-- ,.1 ~/', I..'. ,,j I' ,)(. \- THIS DEED /' .4; Iy1ADE TIrE L day of October in the year of our Lord one thousand nine hundred: ninety-eight q998). BETWEEN CYNIHL\ M MORROW, a widow, GRANTOR, and RICHARD E. BOTTORF, JR, a single man, GRANTEE; WITNESSETH, that in consideration of the sum of SEVENTY THOUSAND NINE HUNDRED (S70,900.00) DOllARS, in hand paid, the ~ccipt whereof is hereby aclcnowledgc<J, the said Grantor does hereby grant and convey to the said Grantee, AlL TIIAT CERTAlN LOT or parcel of groWld situate in the Borough of New CumbcItmd known as Lot No. 49 in the Plan of Lots of"Martin's Addition to the Borough of New C~L1nd, Pennsylvania, II ~d lot fronting twenty-five (25) feet on Bridge Street and extending East along the line ~fLot No. 48, the property now or fonnerly of the Hcin at Law of Ephriam Ebenold, d.euaaed, 0J1 thC North one hWldred fifty-three (153) fcct to the westerly line of a twenty (20) foot wide aDcy Jaio~onaaid Plan of Lots aa Second Alley; thc:nce South along the westerly line of said Second Alley, twcnty-:Uvc (25) feet to the northerly line of Lot No. 50; thence westwardly along the northerly line of Lot No. SO along and tllrough the center of the partition wall separating the property herein dcacnbed andtbe c:aatCr!y haif of said house, one: hundred fifty-tlu1:e (153) feet to the: easterly line ofBridgc Street, the point or Place of BEGINNING. HAVING THEREON ERECTED the northerly h.aI:f of a double 2-1/2 story frame !1welling house and ~own and numbered as No. 617 Bridge Strwt, New Cumberland, Pennaylvania.: . Said Lot being Lot No. 49 on that certain Pbn of Lota swveycd by M B. Cowden, M2)t, 188g, and duly filed among the ~corda in the Office of the Recorder of Deeds in and for CwnberLlnd County inDeed Book "C", Volume 6, Pase 600. BEING the aame ~ which Uoyd Homing. Jr. and Mary E. Homing. his wif~ by ':heir deed dated and recorded August 19, 1977, in ~ed Book J27, Page 230 in the Office of the Record;er of Deeds in and for Cwn,bedand County, granted and conveyed unto W. George Marrow and Cynl!iia M. Morrow, his wife. The said W. George Morrow died on Man;h 6, 1994 whereby title WAS 'VI:lStcd 'solely in Cynthia M Morow by operation of law, the Gnmtor herein. ~d the said. Grantor hereby covenants and agr~ that she will warrant SPECIAl.l.;Y the ptopQ'ty hc:rcby c~ .' BOOK 187. Pi\CE 1iS' , . : (j. ~. I ; r.l '.~ i\..' to .Jo .~ _ """._. .. :'.: . '1 __ .. (. :). .J;";~ f,,.J.,k . . ~ t>- t~ lh'.' A---- ......- ~_. ~~ , ,. .- ~ .. ..... .,,,..;Jr- 4 '.~-- -.' . "~ ' Lt..' '.. ;.; " ,..-,.....~... "'; .\,bt:l\)M Ii; ,':u'.. ,-U ".' ". 1 ,;,. ,"\.,:.a. ......J...,,\.. . IN WITNESS WHEREOF, said Grantor has hereunto set her hand and seal the day and year first above written. WITNESS: (r'j;'!/r /, ,/ /'Ii./ (_;, ~\../'>///I"(i/ o~~:;~.~ ~M. MORROW STATE OF PENNS~ VANIA: SS. COUNTY OFf I/I,//,I////,/ i>)f_ : On this, thej.--t.. day of October:, '1998, before me, the undersigned officer, personally appeared Cynthia M. Morrow known to me (or satisfactorily proven) to be the person whose name is subscribed to lhe within instrument, and acknowledged that she executed same for the purposes therein contained. /'/ , . ////~I/f: I do hereby.certify tl:tat the precis9 r.esidence and complete post office address of the within named Grantee is ~~ '/( r'~'tr//>>7. / 0.tr/'/'c . Y-I/lli Y,/Itj,:I/((/r01/// /;) '''[.'<t./ Date:' 1_" l,rv....... .,~ / 1...._ ,." .c.- 1.;_./ t.. . i /r../ '1)" /, t. ,( ,I////C__\)//~/// I.. Agent for Grantee .. ~99~g~~ffi~:;;;:~ ~:r~:~ ~',......~:a:~gJr:;:;Jg] .-,."..~ c;!j g ~=-~~~~~~~ :;: f~~~r:ii~~~==~ itH~:::~ i ~-< : ~..,., ;:;:l . '=' :z:: : "'" REGI'::U[;j H',' n:F C'.....O.IG!' I. "" ,... ;. .'. " 1 :... v" ,v: .~"=~~7fi ~gr;tl6L"Pl-- ,.. :_.::...,,:.., / i ...Q.OOK 187 rAGE 116 ~ ~ j: 1: .... s-:n:~ <:1 ..r~" ~.. .Cto _ _ _ ~ ...,. ...'::'1 . . . . .. -. - - . - .- >- ,., ';J:;I ..... ." '" UI 1/1 '" .... C"'> ;1- ;;l. <= 'rt ::a rt .... ..... - :7> 0:> ... ~ 6 ~04 B.. -< c.... ,.., "" r- l'J1 ..to 'J'1 C"'> - .-, .....0 :>> ;:.! ~. ~ <= s " a.- -, ..... "'" = :::1 = ::; ..-r~ ~ ..... ~ ....,~ ..... :::;~ ,-" -., ;::: 'J~ ~.Q. '.0 :::I ro ~3 - ... .... 0 - = .- ro C> '1' "... ...... '" r...~ . c.o co ~ c:J --i I-" U1 ;0: .. .. . n: ;"": .~-: ." ~t.J '71 '" r :' ;~ : :'~ .. ~':.1 .. :D ::3 I--" <::) '"" c:,.:) g':.;!'... c: c.: ~~ % rT\ ._ ~ ~~; I CJl.' )'., REL125D CUMBERLAND COUNTY Public Inquiry M2;.p NU:mbe"r Old-Ref 25-24-0811-038 Grantor Grantee(l) (2 ) Address MORROW, CYNTHIA M. BOTTORF, RICHARD E. JR. 617 BRIDGE STREET NEW CUMBERLAND PA 17070 SITUS: Desc. (1) 0617 BRIDGE STREET (2 ) Property Desc. (1 ) (2 ) LOT 49 DB 6C PG 600 (3 ) HOUSE Preferred Land Val Land Val 520 Total Value Improvement Val 5320 5840 Mineral Val F12=Cancel F10=Sales Hist F2=Done CUMBERlAND COUNlY BOARD OF ASSESSMENT Office of Assessment & finance One CourthOuse Square ~ PA 11013 --- Acreage .090 NEW CUMBERLAND BOROUGH WEST SHORE S.D. Land Use Code Consideration Sale Date Deed Bk/Pg Clean&Green? Sqft Bldg Area Gross Area Dimensions Year Built Mobile Home Code Mobile Home Park Mobile Home Mfg. Mobile Home Unit F5=Tax Hist R 3 70900 10/15/1998 187 115 1640 25 153 , . , .. . PENNSYLVANIA DEPARTMENT OF TRANSPORTATION VEHICLE RECORD ABSTRACT .9/07/99 PAGE 1 ..' . , '... .,-_. ._._'.-,,-~._-_.._...,--- OWNER NONE 992500710000164 001 RICHARD E BOTTORF 405 WREN CT MECHANICSBURG PA 17055 LESSEE TITLE NUMBER 36665275 TAG NUMBER TITLE DATE 10/19/84 VIN ZZP20248 REGISTRATION EXPIRY DATE: BODY TYPE MH MAKE ZIMMER ODOMETER READING 3E MODEL *EXEMPT BY FED LAW RENEWAL WID DUPLICATE TITLE COUNT 0 PREVIOUS TAG . _. . VEHICLE YEAR 1984 LIENS YES STOLEN DATE STOPS NO I I ADDRESS CORRESPONDENCE TO: DEPARTMENT OF TRANSPORTATION VEHICLE RECORD SERVICES PO BOX 68691 HARRISBURG, PA 17106-8691 INFORMATION: IN STATE OUT-OF-STATE TDD IN STATE -TDD OUT-OF-STATE www.dot.state.pa.us --- (7:00 AM TO 9:00 PM) 1-800-932-4600 7.17-391-6190 -1'-800-228-0676 717-391-6191 ...- .... COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF TRANSPORTATION SAFETY. ADMINISTRATION HARRISBURG, PA 17123 9/07/99 . '. 231000 INA P.O. BOX 60515 HARRISBURG PA 17106-0000 992500710000164 001 CERTIFICATE a ATTESTATION I hereby certify that Kurt J. Myers, Director of the Bureau of Motor Vehicles of the Depar~ent of Transportation, is the legal custodian of the Motor Vehicle Records of the Pennsylvania Department of Transportation. IN TESTIMONY WHEREOF, I HAVE HEREUNTO SET MY HAND AND SEAL OF THIS DEPARTMENT ON THE ABOVE DATE IN ACCORDANCE WITH SECTION 6103 OF THE JUDICIAL CODE, TITLE 42, PA. Consolidated Statutes. ~ SECRETARY OF TRANSPORTATION I hereby attest that the documents attached hereto for the vehicle listed below are full, true, and correct photostatic and/or microfilm copies of which I have legal custody, and that the copies confor. to the requirements of Section 6109 of the Judicial Code. TITLE: 36665275 VIN ZZP20248 . CERTIFIED IN ACCORDANCE WITH SECTION 6103 OF THE JUDICIAL CODE, TITLE 42, PA. Consolidated Statutes. ~ ;;;.-- KURT J. MYERS, DIRECTOR BUREAU OF MOTOR VEHICLES -- REL125D CUMBERLAND COUNTY Public Inquiry . '. Acreage Map Number Old Ref 10-18-1321-001 TR09833 HAMPDEN TOWNSHIP CUMBERLAND VALLEY S.D. Grantor Grantee(l) (2 ) Address SHAFER, JIMMIE K. BOTTORF, RICHARD E. JR. 405 WREN COURT MECHANICSBURG PA 17055 Land Use Code Consideration Sale Date Deed Bk/Pg T f---" SITUS: Desc. (1) 0405 WREN COURT (2 ) (1) (2) ( 3) Val Val Val Val__ F10=Sales Hist HAMPDEN VILLAGE MHP LOT 405 1985 ZIMMER l4X70 Clean&Green? Sqft Bldg Area Gross Area Dimensions Year Built 980 1985 Property Desc. F2=Done Mobile Home Code Mobile Home Park Mobile Home Mfg. Mobile Home Unit F5=Tax Hist 1025 ZIMMER Preferred Land Land Improvement Mineral F12=Cancel 2210 Total Value 2210 --' CUMBERLAND COUNlY BOARD OF ASSESSMENT Office of Assessment & Finance One Courthouse Square Carlisle. PA 17013 --.,/ --- ",~ROYAL FINANCIAL, INC. POSSESSIOO ROCEIPT J~ie K. , LOAetta F. Shane4 Seller 405 WJten COUllt Sellel: I s AddrC'ss M"C'haniC'-6bUllg. PA 17055 Purchaser hereby stipulates that he/she has personally inspected the mobile home described as: MODEL YEAR 1984 MANUFACTURER z,{rnmeJl MODEL U./1I7IeJl SERIAL NO. ZZP20248 which is loca-ted at 405 WJte.n COUllt Me.c.ha.Yl.-i.C6bUllg, PA 17055 (Address including lot nUnDer) and that he/she accepts the desC'ribed mobile hOITlE? and it C'omplies with all of the Offel: to Puchase/Sale Agreement. Purchasel: fUl:thel: stipulates he/she aC'cepts the. described rrobile home in its present condition and in its present locatioI).- and that he/she has not received any expressea or implied warranties from Seller (s) or from.J~~tk. AmeJlic.a HOlUJina Se4vic.e..6 and/oA ROLla.( Financ.e. of.. PenYL6l/ivan.i.a, Inc.. With only the following exceptions: ( Pie.CUI e .6 e.e. th e a.:ttac.hed PUIlc.hCUI e. AgAe.e.ment) ~~.:-f_ -! Pur:ch er ~~ PUl:chaser , ; ~ -'I~ 3d . ?~ Date Seller's/Broker's Acceptance The written exceptions noted above are Date. verifiediF~&:~;~ ~ll~ 4: ji,:o ~,/e: Selle . -' 1-)..-9/J - r Date Broker ROYAL fINANCE Qf PENNSYL VANIA, INC. 4701 DevoDsLire Road . Suite 105 Hmisburg, PA 17109 (717) 545-6277 / 1-800-356-5048 PURCHASE AGREEMENT By .6.i.grw..tWle. be.law, ..6fLi.d .6e.UeIL(.6} JLmm~e K. , Lo~etta F. Sha~eIL a.nd .6 fLi.d buyel&. {.4 } R~ch~d E. Botto~~ heILe-by a.gJLe.e. to tJuuL6 ac..t on Apltil 30. 1996 .the. .oale 06 a 1984 Zi.nrneIL/Z.irrrneIL 10 ~ 14 liIobill/.. home.. Loc.a.te.d ~ 405 WJren COUllt Mecha.n.~C6 bUlla. PA 11055 the. .6ale. p4ice. 00 $ 11.800.00 60Jt An e.6CJlOw de.po.6U ~a.6 made. on ~n ~he. amount 06 $ ,.-.., -' " The. mobile. home. .4A to be. .oold <UY "UlHERE IS. AS IS" (wUh no" gu.alLa.nte.e. e.x.:te.nde.d by ~. , the. .6e..UelLl' OIL {2) wUh /AJaM.a.YLt.y to Stc.lude. .the. 60Uow.i.ng: . / Se..UeIL and. BUYeIL helLe.by cono-Uun the. mob-i1.e. home. ha6 be.w e-e.-.i.n.6pe.c.t.e4; a.nd. .oaid bUYeILl.o} a.c.c.e.p.t the. concU.ti.on 06 the. .otLid mob-i1.e. home on thio da..te Ap1tU 30~ '1996 the. home. appe.alL6. a6 &JYEI1, f~iJ ~ ~ ~, BUYER: SELLER: Ji,- ~J~ SELLER: ;Y: _ ___ __ . ' ~ I:<OY AL t-II'JAI'J\....IAL, 11\1'-', NAME OF PURCHASER: Rich~d E. BOtto46 SUMMARY OF PURCHASER'S TRANSACTlON- GROSS AMOUNT DUE FROM PURCHASER: CONTRACT SALES PRICE $ 1 7 . 800 . 00 SALES TAX N/ A PHYSICAL DAMAGE INSURANCE PREMIUMS FAMILY PROTECTION INSURANCE PREMIUMS nn.E FEES CLOSING FEES OTHER: 20.00 GROSS AMOUNT DUE FROM PURCHASER S 11 R?O 00 AMOUNTS PAID BYIFOR PURCHASER: . DEPOSIT OR EARNEST MONEY AMOUNT OF NEW LOAN DEPOSIT WITH LENDER APPRAISAL FEE: OTHER: $ 2.273.00 15,147.00 ..; TOTAL PAID BYIFOR PURCHASER S 17,420.00 CASH (GiJ From 0 To) PURCHASER $ ~. "-- /- ..........'-''-'..,''-- ....... 1'-". _..._." . CLOSING DATE: ApJti.l. 30, 1996 NAME OF SELLER: Jimmi~ K. Sha~e4 L04~tta F. Sha'~ SUMMARY OF SELLER'S TRANSACTION GROSS AMOUNT DUE DUE TO SEU.ER: CONTRACT SALES PRICE ITEMS PAlO IN ADVANCE TAXES INSURANCE S11.800.00 OTHER: GROSS AMOUNT DUE TO SEllER: $ 11 . 800 . 00 REDUCTIONS IN AMOUNT DUE SELLER: BROKER FEE PAYOFF TO UENHOLOER ACCRUED INTEREST S 14.269.06 From to CLOSING FEE POSSESSION DEPOSIT PRO RATA TAXES PRO RATA LOT RENT OTHER V / P Vep04U 900.00 2,273.00 'f TOTAL REDUCTIONS DUE SEllER '$ 11 . 44? 0 {, CASH (0 From lflTo) SellER $ 357.94 ~f~~o'f'~ ~, DATE DATE PURCHASER DATE PURCHASER DATE PURCHASER Seller acknowledges receipt of a copy of this statement and au- thorizes disbursement of fu ds as s ted. . .r-2-9l DATE ,,-..2 -9ft, DATE SElleR DATE SELLER DATE JR<<J)Y~ lFnlTIlCID.ITIl~<e (QJ~ JP><ermITIl~yllWCID.ITIlnCID.9 llrm~o 4701 Devonshire Road · Suite 105 Harrisburg, P A 17109 (717) 545-6277 - 1-800-356-5048 May 1, 1 996 Wt / lNrh S h a 6 eJl 19 PutteJl VJU.ve Palm Coa.o~, FL 32.164 Wt. t. MIl.6. Sha6eJL, Plea.oe 6-i.nd enclo.6ed the papeJlWOll.k. MIl. BottOJl,6 .6-i.gned 60ll. the .6ettiement 06 405 Wll.en COUltt MecharUC.6bUllg, PA 17055. We ll.equ..iJte yoUlt .6-i.gnatUlte.6 wheJle maltk.ed by YOUlt -i.n-tt-i.a..f./.l. Plea.oe note the name..o appea/t J-i.mm-i,e K. g LOlletta F. Sha6eJt. It.u -i.mpeJLat-i.ve you. .6-i.gn ail papeJtWoJtk. -i.n that maitYleJL. I have -i.ncluded a bll.-i.e6 explanat-i.on on each 60Jtm a.o to what the 60Jtm ll.eplte..oen:t6, .6houid you. have any need noll. 6U1ltheJl expla.nat-i.on, plea.oe 6ed 6ll.ee to contact me at 1-800-356-5048. Plea.o e .6-i.gn the docwnen:t6, ll.etaA..n YOM check., and ll.etUltn the 60ll.m.6 .{.n the enclo.6ed pac~ge at YOUlt ea/tl-i.e..ot conven-i.ence. Re..opect6uily, r (\] J7 JI(\r~J^lV\Q.,,~V~ Mallyanne K. Paltk. SJt. Loan PllOCe..6.6 all. enc. --; - . PENNSYLVANIA DEPARTMENT OF TRANSPORTATION VEHICLE RECORD ABSTRACT 9/01/99 PAGE 1 OWNER RICHARD E BOTTORF JR 405 WREN COURT MECHANICSBURG PA 17055 TITLE NUMBER TAG NUMBER VIN 524'10174 BSS7293 2G1WX12KXW9323294 MAKE MODEL RENEWAL WID PREVIOUS TAG LIENS STOPS CHEVROLET MZ3 991693901272194 001 YES NO ADDRESS CORRESPONDENCE TO: DEPARTMENT OF TRANSPORTATION VEHICLE RECORD SERVICES PO BOX 68691 HARRISBURG. PA 17106-8691 992440709000351 018 LESSEE NONE 09/02198 EXPIRY DATE: 06/00 CP TITLE DATE REGISTRATION BODY TYPE ODOMETER READING 3fACTUAL HI L EAGE ' DUPLICATE TITLE COUNT VEHICLE YEAR STOLEN DATE 12331: o 1998 INFORMATION: IN STATE OUT-OF-STATE TDD IN STATE TDD OUT-OF-STATE ~ww.dot.stat8.pa.us (7:00 AM TO 9:00 PM) 1-800-932-4600 711-391-6190 .1"'800-228-0676 711-391-6191 --- ,. COMMONWEALTH 'OF PENNSYLVANIA DEPARTMENT OF TRANSPORTATION ,SAFETY ADMINISTRATION HARRISBURG, PA 17123 9/07/99 ~ ..t' ... 231000 INA P.O. BOX 60515 HARRISBURG PA 17106-0000 992500710000164 002 CERTIFICATE a ATTESTATION I hereby certify that Kurt J. Myers, Director of the Bureau of Motor Vehicles of t~e Depart~ent of Transportation, is the legal custodian of the Motor Vehicle Records of the Pennsylvania Department of Transportation. IN TESTIMONY WHEREOF, I HAVE HEREUNTO SET MY HAND AND SEAL OF THIS DEPARTMENT ON THE ABOVE nATE IN ACCORDANCE WITH SECTION 6103 OF THE JUDICIAL CODE, TITLE 42, PA. Consolidated Statutes. ~' SECRETARY OF TRANSPORTATION I hereby attest that the documents attached hereto for the vehicle listed below are full, true, and correct photostatic and/or microfilm copies of which I have legal custody, and that the copies conform to the requirements of Section 6109 of the Judicial Code. TITLE: 52410174 TAG BSS7293 VIN 2GIWX12KXW9323294 CERTIFIED IN ACCORDANCE WITH SECTION 6103 OF THE JUDICIAL CODE, TITLE 42, PA. Consolidated Statutes. ~ :;;.-- KURT J. MYERS, DIRECTOR BUREAU OF MOTOR VEHICLES --- .' >l" ~ '.. PENNSYLVANIA DEPARTMENT OF TRANSPORTATION VEHICLE RECORD ABSTRACT . 9/07/99 PAGE 1 992500710000164 002 OWNER RICHARD E BOTTORF JR 405 WREN COURT MECHANICSBURG PA 17055 LESSEE NONE TITLE NUMBER TAG NUMBER VIN 52410174 BSS7293 2G1WX12KXW9323294 TITLE DATE REGISTRATION EXPIRY DATE: BODY TYPE ODOMETER READING 3EACTUAL MILEAGE DUPLICATE TITLE COUNT VEHICLE YEAR STOLEN DATE 09/02/98 06/00 CP MAKE MODEL RENEWAL WID PREVIOUS TAG LIENS STOPS CHEVROLET MZ3 991693901272194 001 1233E o 1998 YES NO ADDRESS CORRESPONDENCE TO: DEPARTMENT OF TRANSPORTATION VEHICLE RECORD SERVICES PO BOX 68691 HARRISBURG, PA 17106-8691 INFORMATION: IN STATE OUT-OF-STATE TDD IN STATE _ TDD OUT-OF-STATE www.dot.state.pa.us (7:00 AM TO 9:00 PM) 1-800-932-4600 717-391-6190 _-1~800-228-0676 717-391-6191 ..-'" (") ~ "- ~}{~~. ""-r': f'; 1"-.:1 = = er- e CJ -4 l" 0"' ~ ::;.! -'--r1 In r= -0 no ~[JQ C) rl..) ::i;.:r, C.J ('5 (3m :::-\ iJ =< :r->" --.. \.0 (J) C.r. . PAMELA S. DENT f/k/a PAMELA S. BOTTORF, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. RICHARD E. BOTTORF, Defendant NO. 06 - 4658 Certificate of Service of Petition and Rule to Show Cause I hereby certify that the following actions were taken in serving Pamela S. Dent, f/kJa Pamela S. Bottorf in this matter. 1. On September 29,2006 at 3:21 PM a Petition to Strike Foreign Judgment was filed of record with the Prothonotary. 2. On September 29,2006 at 4:05 PM a twenty four (24) page Petition to Strike Foreign Judgment was faxed and mailed by postage prepaid, first class U.S. Mail to Plaintiffs counsel of record, John P. Neblett, Esquire as shown on Exhibit "A" (cover page and transmission verification report). 3. On October 10,2006 the Court issued an Order in this matter. 4. On October 12,2006 the Order and Petition to Strike Foreign Judgment were faxed and mailed by postage prepaid, first class U.S. Mail to Plaintiffs counsel of record, John P. Neblett, Esquire as shown on Exhibit "B" (cover page and transmission verification report). 5. On October 12,2006 the Order and Petition to Strike Foreign Judgment were sent by U.S. Priority Mail with Delivery Confirmation Requested to the Plaintiff s last known address. 6. The Order and Petition to Strike Foreign Judgment were delivered 7:15 AM on October 14, 2006 as shown on Exhibit "C". 7. Ms. Dent's personal attack and complaints about delays in receiving mail are false or frivolous because her counsel of record, John P. Neblett, Esquire received the documents on September 29,2006 in accordance with the Pennsylvania Rules of Civil Procedure. Respectfully submitted, BY: St en well, squire owell Law Finn 619 Bridge Street New Cumberland, PA 17070 (717) 770-1277 Voice Supreme Court ID 62063 Attorney for the Defendant Certificate of Service I hereby certify that on the date set forth below a true and correct copy of the foregoing document was served upon the party/parties set forth below by postage prepaid, first class United States Mail addressed as follows: Date: October 27, 2006 Pamela S. Dent P.O. Box 740208 Orange City, FL 32774 ~ e ~, Jteven Jiowett Attorney at Law 619 BrIdge street. New cumberland, pennsylvania 17070. Telephone 717-770-1277 · Fax 717-770-1278 TO: 'J c ",-" ~. ~ Q.\'" \~\-+ E s 't Ll \ ; t / FAX NUMBER ~'\\- qq~~ V STEVEN HOWELL, ESQUIRE FROM: DATE: 9Ia,\'\D~ ~-\-'. OS Q vV\ TIME: TOTAL PAGES cl '-\ (Including Cover Sheet) SUBJECT: \) Q..('\\- \i. ~ 0 '\\01" f ( .\) 0 A A\-..:. LA \\ U -...v ; ^ fM. ^' \ \ '-- f'l " I ^ '1"\ r"" .\. IMPORTANT NOTICE The information contained in this message is confidential and may be attorney client privileged and it is intended only for the use of the individual or entity named above. If the reader of this message is not the intended recipient, you are hereby notified that any dissemination or distribution of this communication to anyone other than the intended recipient is strictly prohibited. If you have received this communication in error, please notify us by telephone immediately and return the original message to us at the above address via the United States Mail. If you have any questions regarding this transmission please telephone (717) 770-1277 between 8:00 AM and 4:00 PM East~rn Standard Time. Thank you. I,-~!, ..J -- TRANSMISSION VERIFICATION REPORT .' TIME NAME FAX TEL SER.# 09/29/2006 16:16 HOWELL LAW FIRM 71 77701278 000A6J528632 DATE, TIME FAX NO./NAME DURATION PAGE(S) RESULT MODE 09/29 15: 11 6719938 00:05:45 24 OK STANDARD ECM " . I cSteven 2/owett Attorney at Law 619 Bridge street. New Cumberland, Pennsylvania 17070. Telephone 717-770-1277. Fax 717-770-1278 **** VIA TELECOPIER 671-9938 **** October 12,2006 John P. Neblett, Esquire Suite 204 2000 Linglestown Road Harrisburg, P A 17110 RE: Dent v. Bottorf, No. 06-4658 (Cumberland County, Pennsylvania) Dear John: As a follow up to our conversation on September 29,2006 at 4:20 PM, this letter confirms that: (a) you will not be representing Ms. Dent in this matter; and (b) I should serve Ms. Dent directly by U.S. Mail. I intend to forward to her the Order and Petition by U.S. Priority Mail today unless I receive written instructions from you to the contrary indicating you will be representing her interests in state court. I enclose a copy of the Order and Petition to satisfy service requirements set forth in,-r6 of the Order. Copies will be sent by U.S. Mail to your office as well. Please call me if you have any questions. Very truly yours, SH/bth Enclosures ,t>>, . . . TRANSMISSION VERIFICATION REPORT / . TIME NAME FAX TEL SER.# 10/12/2005 12:20 HOWELL LAW FIRM 7177701278 000A5J528532 DATE,TIME FAX NO./NAME DURATION PAGE(S) RESULT MODE 10/12 12:14 5719938 00:05:03 25 OK STANDARD ECM USPS - Track & Confirm Page 1 of 1 . . Home I ~ _:;.::.<:"r:'":'fSJ'~:\;~;:(";1Hl:[::;t"~:Z~!J:'::]"r=~:;;;P~..-_-i_'___~!.~M:;-t':'F:G(::<.t~r:~'1 30ZJjiiLI;t2J::>>::~;i.>:::>(}):;'<:;::";LH22SJ:LL2L~}:.:::::(>::-:<<:"i':'::::<:}}i- " _' :.~" "'_"'_'_"""""';;::;:';:'.:~;:;;:';;"::"""_""'~".c.....;.....'.'...;.".'..;.".....;.....::::-:'..-....'.. c.'.".;;;"'" '-_._......:..:;:;:;:;;;,,__...,........::;.;;..;;;;;:::',;~::..;:.-.. ..,....::.,... .,0-_ Track & Confirm Track &. Confirm Search Results Label/Receipt Number: 0305 0830 0002 0270 9096 Detailed Results: . Delivered, October 14,2006,7:15 am, ORANGE CITY, FL 32774 · Acceptance, October 12,2006,5:08 pm, CAMP HILL. PA 17011 c;8~.~) rii.tiic(;,'tiJiiiii$:;;;;;'ili;;;';;;) '" ,,'..-- \_-'"-"-"---"------~ _""_m"_~'"._".""':.-""_""~ Track fa Confirm c Enter Label/Receipt Number. I ( ~~9ptiQllS Track & Confirm by email Get current event information or updates for your item sent to you or others by email. (G~~) . POSTAL INSPECTORS Preserving the Trust site map contact us government services jobS National & Premier Accounts Copyright@ 1999-2004 USPS. All Rights Reserved. Terms of Use Privacy Policy U.S. Postal ServiceTllDelivery ConfirrnationTll ~11ft if!. Postage and Delivery Conflnnatlon fees must be paid before 11l1- t:J ArIIcIe Sent To: (Ill be CCIIIIpIlIlId..,""'" ... m: ? A.M~\1r S \)-IC..,f\'\ ~ ~ T~ p:,tx .., "'\0 aO ~ ~ t:J Or At-t'1e c:.,'~ r L3.~ 7'7 Ll I t:J POSTAL CUSTOMER: !i ; """"". ' Keep this receipt For Inquiries: 8 t:J HEife..' Access Internet :b site at m fTl ' ,;\ ~~f~~~-1811 ~:(~... ~~(POStS;:~ ,......'. ~ \;: b "I0'Prlorlty Mall-58 ' t:J DFlrat-C1as8 . parcel DPackage SeMcet perceI P8 Form 152. May 2002 (8N "--I c "~, ii"J"'- http://trkcnfrml,smi.usps.com/PTSlntemetWeb/lnter LabelDetail.do 10/27/2006 Q C,_ ?:.~- ri!~ rio', r-) = t~::.:) cr" o ,,-) .-1 W o --n :? ,.-n flli;:Z ~~~? t~.j ::::.~g.~. ~ ~.~.- . .~; '--;"~:~. ~ C) ..\.-~ ; ~-;I ?TI ',..j ~n ~< . .'" .. . 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 1 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA 2 3 4 PAMELA S. DENT F/K/A PAMELA S. BOTTORF, PLAINTIFF t-".) <:) g ~~ c:r- _, :-" c::l a=~ t4 6 ftl "" I ~)~ " co 5 VS NO. 6 7 RICHARD E. BOTTORF, DEFENDANT f,.~ ~'" 8 9 DEPOSITION OF: RICHARD E. BOTTORF TAKEN BY: DEFENDANT BEFORE: ANTHONY J. BALSHY, REPORTER NOTARY PUBLIC DATE: NOVEMBER 15, 2006, 11:12 A.M. PLACE: 619 BRIDGE STREET NEW CUMBERLAND, PENNSYLVANIA APPEARANCES: STEVEN HOWELL, ESQUIRE FOR - DEFENDANT \..... ~ ~:P rnr- -om :pC(' ~ )--) ?i :.r, ~!- -j"" ';~o 3m ,--\ ?o =< .....lh - .. 0) .;::- GEIGER & LORIA REPORTING SERVICE 1-800-222-4577 . . . 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 2 1 TABLE OF CONTENTS 2 3 WITNESS 4 FOR DEFENDANT DIRECT Richard E. Bottorf 5 5 6 7 8 9 EXHIBITS EXHIBIT NO. PRODUCED AND MARKED A - Docket sheet 8 B - Physician letters 9 C - 641 Support 1984 docket sheet 15 D - Chapter 13 trustee report 23 E - E-mails 24 GEIGER & LORIA REPORTING SERVICE 1-800-222-4577 . 1 2 3 4 5 6 7 8 9 10 11 12 . 13 14 15 16 17 18 19 20 21 22 23 . 24 25 3 RICHARD E. BOTTORF, called as a witness, being sworn, testified as follows: MR. HOWELL: Good morning, Richard. I want to put something on the record before we commence that the plaintiff was notified by US Express Mail of this deposition commencing at 11:00 today, November 15, 2006, at 11:00. This was delivered to Ms. Dent's PO Box at 10:07 A.M. on Thursday, November 9, as shown on a U.S. Postal Service website. On November 14, Ms. Dent sent to me two letters basically objecting to the deposition and demanding in the two faxes essentially to, one, have a list of questions I intended to ask her so they could be reviewed by a Florida attorney, number two, that I had to guarantee a copy of the transcript would be in her hands no later than the close of business on Friday, November 17, 2006, and, three, that I needed to give her a written explanation as to why she or Richard needed to be deposed in this case. I advised Ms. Dent via fax letter on Tuesday afternoon that she could participate GEIGER & LORIA REPORTING SERVICE 1-800-222-4577 . 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 . . 4 vla telephone in both her deposition as well as the deposition of Mr. Bottorf. That would not be a problem, but that I could not reschedule the deposition since the deadline for depositions set by the Honorable Judge Hess is November 24, the day after Thanksgiving, and I will be out of the office in Europe from November 19 r'm leaving New York and I won't return till November 29. With that said, at 11:00 precisely in the presence of the court reporter and my client, we placed a telephone call on speaker phone to the last known telephone number of Ms. Dent's employer. She has provided no telephone number to contact her in the case, but there was a phone number on a Fed Ex package to her employer and we dialed area code 407-647-1616 at 11:05 A.M. and I was told in the presence of the court reporter and the witness, my client, that she was present in the office but on the telephone at the time. I left a voice mail message saying that we were going to commence the deposition in five minutes and asked her to return the call and that we were going to start GEIGER & LORIA REPORTING SERVICE 1-800-222-4577 . 1 2 3 4 5 6 7 8 9 10 11 12 . 13 14 15 16 17 18 19 20 21 22 23 . 24 25 5 precisely at 11:12 A.M. It is 11:15 A.M. and there is no call from Ms. Dent, so we going to start with Mr. Bottorf. DIRECT EXAMINATION BY MR. HOWELL: Q Mr. Bottorf, I think you have been sworn in, so I want to ask you a couple of questions. Are you on any medications as we speak? A Q A Yes, I am. What are they? 1'm on a Duragesic patch, 100. It's an opiate. Q A Q Are you on painkillers? Yes. And are these prescription medications? A Q Yes, they are. Aside from painkillers prescribed by your doctor, are you on any other kind of medication? A Not at this time. Q Have you taken any alcohol in the GEIGER & LORIA REPORTING SERVICE 1-800-222-4577 . 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 . . 6 last 24 hours? A No. Q Is there anything aside from the medications that you're on that would affect your ability to testify truthfully or accurately today? A No. Q If you don't understand a question, I want you to tell me you don't understand and repeat it. If you don't know an answer to a question, you shouldn't guess. You should say yes or no or I don't know or glve an explanation as to what the answer would be. Now, what's your name, age and address? A Richard Bottorf, 810 Sherwood Road, New Cumberland, Pennsylvania. number is 724-1836. The phone Q A Q A Q A Now, are you employed in any way? No. Are you married? Yes. And who are you married to? Brenda Bottorf. Q How long have you been married to GEIGER & LORIA REPORTING SERVICE 1-800-222-4577 . 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 . . 7 her? A Q Six years. Were you once married to a Pamela S. Bottorf now known as Pamela S. Dent? A Q Yes, sir. If I refer to Pamela Bottorf, you should assume I'm referring to Pamela Dent and vice versa for the purpose of this deposition. Okay? A Yes, Slr. Did you have a child with a Q Pamela S. Bottorf? A Yes. Q Is the child's named Lindsey Bottorf with a date of birth November 24, 1990? A Q Yes. Did Pamela S. Bottorf file a complaint for child support against you in the Cumberland County Domestic Relations section on June 18, 1992? A Q Yes, she did. Did Pamela S. Bottorf then file a second child support complaint against you in the Cumberland County Domestic Relations section on August 3, 1993? GEIGER & LORIA REPORTING SERVICE 1-800-222-4577 . 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 . . 8 A Yes. Q Were both child support cases filed by Pamela S. Bottorf in the Cumberland County Domestic Relations section docketed under Case No. 595 Support 1992 and DR20l96? A Yes, sir. Q Have you brought with you certified copies of the docket sheet in the case 595 S 1992 with you today? A Yes, sir. MR. HOWELL: Let's have these marked as Defendant's Exhibit A. (Docket sheet marked as Defendant's Exhibit A.) BY MR. HOWELL: Q Now, at anytime since June 18, 1992, have you ever filed a written consent with the domestic relations section of Cumberland County to permit Florida or Flagler County in Florida to assume any jurisdiction or modify any child support orders or do anything with your child support cases originally filed ln pennsylvania? A No. Q Were you disabled from all GEIGER & LORIA REPORTING SERVICE 1-800-222-4577 . 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 . . 9 employment on or about May 15, 1997? A Yes. Q Did President Judge Hoffer issue an order on August 11, 1997, stating that, "It is hereby ordered and directed that the support order be suspended effective May 15, 1997, due to cervical spine surgery. Defendant meaning you -- was unable to work and has no income from any other source"? A Yes, sir. Q Did you bring several letters from your physician regarding your disability with you today? Yes. MR. HOWELL: Now, let's have this marked as Exhibit B. A (Physician letters marked as Defendant's Exhibit B.) BY MR. HOWELL: Q Now, directing the witness, we are going to go through that Exhibit Beach letter. Turning to the first letter, who is Rodney Hough, H-O-U-G-H, M.D.? A That's Rodney Hough. Q Who is he? GEIGER & LORIA REPORTING SERVICE 1-800-222-4577 . 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 . . 10 A Q He was my family doctor. Does his letter of December 7, 1998, which is attached as the first document in Exhibit B state, "The patient has been treating conservatively over the past year but is now to the point where he is totally disabled. The patient has quite a bit of incentive to work but is physically unable to"? A Q Yes. Is the next document, Richard, if you turn to the next one, is the next one in Exhibit B a statement of an attending physician dated June 23, 1999, by a Dr. Rodney K. Hough, M.D.? A Q Yes. At line six of the letter dated June 23, 1999, does he write, "Date patient able to return to work, not at this time"? A Yes. Q Having read Ms. Dent's response to our petition to strike the foreign judgment and her claims of domestic violence, is the next document a letter from David M. Rosenthal, M.D., does that letter from David M. Rosenthal, M.D., state, "Careful review of Richard's GEIGER & LORIA REPORTING SERVICE 1-800-222-4577 . 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 . . 11 history as well as current presentations reveals no signs indicative of aggression, assaultiveness, danger to self or others. At this point nothing would appear to indicate any difficulties or danger with him spending time with his daughter and there does not appear to be any need for special supervisions"? Does it state that? A Q A Yes. Is Dr. Rosenthal a psychiatrist? Yes, he 1S. Q Was he treating you for depression arising from your inability to work? A Yes. Q Did Dr. David M. Rosenthal, M.D., write a letter dated August 18, 1999, in which he states that you are "unable to work"? I believe that's the next one in Exhibit B. A Yes. Q Did a Dr. Willis W. Willard, M.D., treat you as well? A Yes. Q A And who is Dr. Willis W. Willard? He is a doctor in the same practice with Rodney Hough, and he was also a GEIGER & LORIA REPORTING SERVICE 1-800-222-4577 . 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 . . 12 practicing physician on my case on the team of doctors that were involved. Q Did Dr. Willis Willard write a letter on your behalf of August 19, 1999, in which he indicated to Judge Hoffer that following a court appearance, you suffered a, quote, temporal lobe seizure in the courtroom during the hearing? A That is true. Q Is that letter contained within the Exhibit B there? A Q Yes, it 1S. Did a clinical neuropsychologist named Paul J. Enslinger evaluate you in 1999? A Yes. Q Did Dr. Enslinger write a letter dated September 14, 1999? A Yes. Q Did this letter state, "He -- meaning you, Richard Bottorf -- is currently being evaluated by the Bureau of Disability Determination, and I have supported his disability at this time"? A Yes. Q Are all these letters included in GEIGER & LORIA REPORTING SERVICE 1-800-222-4577 . 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 . . 13 Exhibit B? A Q Yes. The next one 1n order in Exhibit B, 1S this a statement of attending physician dated August 26, 1998, signed by a Steven B. Wolf, M.D.? A Yes. Q On line six where it states date patient able to return to work, does it state, "Totally disabled, unknown"? A Yes. Q Who 1S Dr. Wolf? A He was the surgeon that performed the neck surgery. Q I want to turn your next attention to the next one in Exhibit B. Is this a statement of attending physician completed by a Steven B. Wolf of the Orthopedic Institute of Pennsylvania dated December 1, 1998, for you? A Yes. Q On line five in response to this question, is patient disabled from performing any occupation or any work for compensation or profit, does he checkmark yes? GEIGER & LORIA REPORTING SERVICE 1-800-222-4577 . 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 . . 14 A Yes. Q Does he then fill in totally disabled, unknown? A Q Yes. Next in order, lS this a physician's information request form from Domestic Relations of Cumberland County filled out by Steven Wolf, M.D., on March 20, 1998? A Q Yes. And in this physician's information request form, does Dr. Wolf certify, quote, the patient has been continuously disabled, unable to work from 5/15/97 through present? A Q Yes, it does. Turning next in order, is this a statement of attending physician dated April 29, 1998, from a Steven B. Wolf of the Orthopedic Institute of Pennsylvania regarding you? A Q Yes. Does it indicate that your ability to return to work is unknown? A Yes. Q Finally, is the last page an GEIGER & LORIA REPORTING SERVICE 1-800-222-4577 . 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 . . 15 Orthopedic Institute of Pennsylvania doctor's note, a form, preform filled out by a Dr. Wolf indicating, quote, the patient, the above-patient, meaning Richard Bottorf, lS presently totally disabled? A Q Yes, it does. Are all those documents that you have received personally from these physicians? A Yes. Q Now, have you brought certified copies of the docket sheet in the case 641 Support 1984? Yes. MR. HOWELL: Let's have this marked as Exhibit C. A (641 Support 1984 docket sheet marked as Defendant's Exhibit C.) BY MR. HOWELL: Q Does Exhibit C involve your first wife, Tracy J. Bottorf, seeking child support for a Brook E. Bottorf, date of birth 4/3/1983? A Yes. Q Does Exhibit C include an order dated August 11, 1997, in which Judge Hoffer determined that you were unable to work at all GEIGER & LORIA REPORTING SERVICE 1-800-222-4577 . 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 . . 16 effective May 15, 1997? I believe it's the third page in. A Yes. Q Does Exhibit C include the July 13, 1999 order in which Judge Hoffer denied your first wife's efforts to reinstate the child support order? A Yes. Q Does the July 13, 1999 order state, "The plaintiff -- this is referring to your first wife -- the plaintiff's petition for reinstatement of the order is denied as the defendant has provided verification to DRO -- meaning domestic relations -- that he is still disabled and unable to pay support"? A Yes. Q Does Exhibit C include the August 19, 1999 order in which states, "And now this 19th day of August, 1999, testimony having been taken as to the defendant's ability or inability to work because of a medical condition, we do find that past medical condition continues and that at the present time he -- meaning you -- has no ability to perform gainful employment. Should the GEIGER & LORIA REPORTING SERVICE 1-800-222-4577 . 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 . . 17 defendant be successful in his request for social security disability income, he is directed to immediately notify the domestic relations office of that situation." A Q Yes. Returning to Exhibit A, was a Florida child support order registered in Pennsylvania in January 1998? A Q Yes. Less than six months later, was this child support order terminated in this case? A Q Yes, by Pamela Dent. Does Exhibit A include an order of court dated June 5, 1998? Direct your attention to that. Does Exhibit A include an order of court dated June 5, 1998, which states effective May 13, 1998, the support order is terminated due to, "The plaintiff's request to stop services through Florida and Pennsylvania, arrearage set at $8,279.67"? A Q Yes. What was the reason your obligation to pay child support to Pamela S. Bottorf now Pamela S. Dent was terminated GEIGER & LORIA REPORTING SERVICE 1-800-222-4577 . 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 . . 18 effective May 13, 1998? A I was unable to have gainful employment. Q Do you believe the effective date of your obligation to pay child support to Pamela S. Bottorf should be the same as the case involving Tracy J. Bottorf which would be May 15, 1997? A Yes, I do. Q Is May 15, 1997, the date that Judge Hoffer in the other Cumberland County domestic relations case indicated that all support obligations were suspended because of your disability? A Q Yes, it is. And inability to gain any employment. Now, if you were unable to work in the Tracy Bottorf versus Richard Bottorf case, then you were also unable to work in the Pamela Bottorf versus Richard Bottorf case, correct? A Q Yes. And she was aware of that. Have you reviewed the documents submitted by Pamela Bottorf in support of her Florida judgment? A Yes. GEIGER & LORIA REPORTING SERVICE 1-800-222-4577 . 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 . . 19 Q Do these documents include thousands of dollars in child support alleged to have accrued after May 13, 1998? A Yes. Q Do these documents include $3,197.10 in alleged child support for the period May 13, 1998, through December 31, 1998? A Q Yes. Do these documents include $3,140.85 in alleged child support for the entire year of 1999? A Q Yes. Do these documents include $2,268.45 in alleged child support for entire year of 2000? A Q Yes. Do these documents include another $812.88 in alleged child support for the first six months of 2001? A Q Yes. Without any interest charges on these sums, would you agree that Pamela S. Bottorf's documents in support of her Florida judgment show $9,419.28 in alleged child support owed by you after Judge Hoffer GEIGER & LORIA REPORTING SERVICE 1-800-222-4577 . 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 . . 20 terminated the support order on May 13, 1998? A Q Yes. Do these documents ln the Florida judgment supported by Ms. Bottorf show you to be charged eight percent compounded interest on this $9,419.28 since at least July 1, 2001? A Yes, it does. Q From July 1, 2001, to July 1, 2002, was the interest on this $9,419.28 at least $753.54? A Yes. Q From July 1, 2002, to July 1, 2003, was the eight percent compounded interest on this $10,172.82 another $813.82? A Yes. Q From July 1, 2003, to July 1, 2004, was this eight percent compounded interest on this balance of $10,986.64 an additional $878.93? A Q Yes. From July 1, 2004, to July 1, 2005, was another eight percent compounded interest on this new balance of $11,865.57 total $949.24? A Yes. GEIGER & LORIA REPORTING SERVICE 1-800-222-4577 . 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 . . 21 Q Would you agree that the $9,419.28 ln alleged child support owed by you according to Ms. Dent after Judge Hoffer terminated the support order ln 1998 has increased with the interest to $12,814.81? A Q Yes. Now, have you ever seen any legal justification for the charging of eight percent compounded interest? A The first time I saw it was when I was notified. Q But this is something she's put down? A Absolutely. Q Do you believe that you owe $12,814.81 in child support from Florida plus eight percent compounded interest after Judge Hoffer's June 5, 1998 order terminating the child support effective May 13, 1998? A No, I did not. Q Prior to the summer of 2005, were you aware that there was any child support being charged to you after May 13, 1998? A No, and I personally thought that the extra from social security was actually GEIGER & LORIA REPORTING SERVICE 1-800-222-4577 . 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 . . 22 going towards doctors' bills which it was not. Q When did you come to learn that Pamela S. Bottorf had not suspended the Florida action as she had represented to the court, Judge Hoffer, and you on June 5, 1998? A I don't know the exact date, but she tricked me to come down to Florida to visit the daughter, and I was surrounded by police and arrested and thrown In a Florida prison. Q How long did you spend in the Florida prison in the summer of 2005? A Q 28 days. How much money did it take for you to be released from prison? A Q Around $10,000. Now, did you come to file a chapter 13 bankruptcy in March 2005 docketed to No. 10501521 in the Middle District of Pennsylvania? A Yes. Q As part of that bankruptcy, did Ms. Dent receive $1,789.58 through payments from the chapter 13 trustee as shown on Exhibit D? A Yes, she did. GEIGER & LORIA REPORTING SERVICE 1-800-222-4577 . 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 . . 23 MR. HOWELL: Let's have Exhibit D marked. (Chapter 13 trustee report marked as Defendant's Exhibit D.) BY MR. HOWELL: Q Is John P. Neblett the attorney for Ms. Dent in the bankruptcy proceeding? A Yes. Q And he is also the attorney in this proceeding of record initially? A As I know. Q Is he the individual to whom the $1798 was paid or $1789.58 according to what the chapter 13 trustee's printout shows? A Yes. Q Are you aware that Ms. Dent has written to Judge Hess in a letter dated October 25, 2006, the following statement, "In addition I fear for my safety if I were forced to attend the hearing in person. To this day I live in fear of the defendant and those around him who might seek to do me harm because of threats directed to me by the defendant in the past"? Are you familiar with that? A Yes, I am. GEIGER & LORIA REPORTING SERVICE 1-800-222-4577 . 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 . . 24 Q In the summer of 2005, and I'm addressing now this issue of her fear of you. In the summer of 2005 did she place a telephone call to you and ask you whether or not you wanted to start a new relationship with your daughter, Lindsey? A Yes, she did. Q In the summer of 2005, did you and Ms. Dent start to communicate bye-mail regarding your daughter? A Q Yes, we did. Did you bring these e-mails with you today? A Yes, I did. MR. HOWELL: marked as Exhibit E. Let's have these (E-mails marked as Defendant's Exhibi t E.) BY MR. HOWELL: Q Now, those e-mails are in order, chronological order, Richard, so we will go through them in this way. Now, in an e-mail on June 26, 2005, at 10:04 P.M. does Ms. Dent write the thought occurred to me that it might be nice if you, Brenda, and I'm assuming Brenda GEIGER & LORIA REPORTING SERVICE 1-800-222-4577 . 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 . . 25 is your current wife, Brenda Bottorf, and I could meet for dinner Friday evening? It would be a good change for us to talk and get a bit more comfortable with each other. Plus Brenda and I have not met. I am thinking that if the three of us are comfortable with each other, then this will make things easier for Lindsey on Saturday. Did you receive such an e-mail? A Q Yes, I did. Is there a series of e-mails in late June 2005 through early July 2005 between you and Ms. Dent that's contained within Exhibit E? A Q Yes, there lS. Would it be fair to say that nowhere In any of these e-mails does Ms. Dent express any fear of you? A Q Nowhere. Does she offer to make hotel reservations for you? A Yes, she does. Q Did she tell you where the Steak and Shake Restaurant is? A Yes, she does. Q Does she tell you where Sonny's GEIGER & LORIA REPORTING SERVICE 1-800-222-4577 . 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 . . 26 Barbeque is? A Q Yes, she does. Does she talk to you about how she enjoyed the latest Star Wars movie? A Yes, she did. Q Does she talk to you about your puppies that were just born? A Yes, she does. Q Does she talk about you offering to give a computer to Lindsey? A Yes, she does. Q Now, what happens when you arrive in Florida just so we know? And when did you arrive in Florida? Is it around July of '05? A It was about the middle of July. I arrived in Florida to meet her at the Steak and Shake, and I was surrounded by Florida sheriffs, immediately taken away and put In a Florida prison. Q Now, in terms of legal fees, how much did you incur in that? A About 8,000 in legal fees. Q Did you have to pay anything to get out of jail towards the child support? A No. GEIGER & LORIA REPORTING SERVICE 1-800-222-4577 . 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 . . 27 Q Now, aside from the $8,000 legal fees, you spent 26 days ln jail? in A Q A Q 28. 28 days in jail? Yes. Did she also get a reward for turning you in? A Q A Yes, she did. How much did she get? $2500. Q Now, are you asking the Pennsylvania court to strike her judgment for $34,373.46? A Yes, I am. Q Did you ever agree to Florida assuming jurisdiction over this child support case? A Q No. Are you asking this court to strike any judgment which seeks child support after May 13, 1998, ln light of Judge Hoffer's June 5, 1998 order? A Yes, I am. Q Having reviewed the Florida judgment filed ln Pennsylvania, do you know it GEIGER & LORIA REPORTING SERVICE 1-800-222-4577 . 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 . . 28 includes at least $9,419.80 in alleged child support after May 13, 1998, through July 1, 2001? A Yes. Q Having reviewed the Florida judgment filed 1n Pennsylvania, do you know it to contain at least another $3,395.53 in interest compounded at eight percent on the balance of $9,419.80? A Yes. Q Having reviewed the Florida judgment filed in Pennsylvania, do you know that it does not provide you with any credit for the $1,789.58 paid by you through the bankruptcy court to her attorney for her claim? A Q Yes. Is it your position that the Florida judgment is inflated by no less than $14,604.91? A Yes, it 1S. Q Is it your position that the Florida judgment is inflated by child support for the period May 15, 1997, through May 13, 1998, because you were unable to work as of May 15, 1997? GEIGER & LORIA REPORTING SERVICE 1-800-222-4577 . 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 . . 29 A That is correct. Q Is the Florida judgment, and 1'm speaking as to the period of time May 15, 1997, through May 13, 1998, are the documents presented by Ms. Dent seeking $5,115.36 In alleged child support for the period May 15, 1997, through May 13, 1998? A Yes. And, of course, you couldn't work Q after May 15, 1997? A Q No, sir. And that decision was backed up by Judge Hoffer's several orders on that issue? A Yes, it lS. Q Now, is the Florida judgment inflated by another eight percent compounded interest on this $5,115.36 alleged to have accrued for the period May 15, 1997, through May 13, 1998? A Yes, it lS. Q Does the eight percent compounded interest on the $5,115.36 for the period alleged to have accrued from May 15, 1997, through May 13, 1998, total, and I am going to give you an amount of interest for each year GEIGER & LORIA REPORTING SERVICE 1-800-222-4577 . 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 . . 30 and you tell me if you agree with these calculations: For 1998 to 1999, May 13 to May 13, $409.22? A Yes. Q From May 13, 1999, to May 13, 2000, $441.96 at eight percent interest? A Yes. Q From May 13, 2000, through May 13, 2001, another $477.32 in eight percent compounded interest? A Yes. Q From May 13, 2001, to May 13, 2002, $515.50 at eight percent compounded interest? A Yes. Q From May 13, 2003, through May 13, 2004, another $601.28 in compounded eight percent interest? A Yes. Q From May 13, 2004, to May 13, 2005, another $649.39? A Q Yes. Does that interest at eight percent compounding interest on a balance of $5,115.36 increase the Florida judgment by GEIGER & LORIA REPORTING SERVICE 1-800-222-4577 . 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 . . 31 $3,651.41? A Q Yes, it does. Now, one final question: Assuming you were incapable of working as Judge Hoffer said May 15, 1997, and reviewing the paperwork submitted by Ms. Dent in her Florida judgment recorded here in Pennsylvania, have you determined that -- and I am going to give you a series of amounts and a category of what it is. Have you determined that these following amounts are improper in your opinion because you don't owe the money because you were incapable of working? And here is the first figure, $9,419.80 in alleged child support from May 13, 1998, through July 1, 2001? A Q Yes. You agree you do not owe that? A I agree I do not owe that. Q Do you agree that you do not owe $3,395.53 1n interest at eight percent compounded on this $9,419.80? A I agree I do not owe that. Q And that 1S part of her judgment? A Yes, it is. GEIGER & LORIA REPORTING SERVICE 1-800-222-4577 . 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 . . 32 Q Do you agree that you never owed $5,115.36 1n child support alleged to have accrued to her 1n Florida from May 15, 1997, through May 13, 1998? A I agree I do not owe that. Q Do you agree that you do not owe $3,651.41 in eight percent compounded interest on the balance of $5,115.41? A I agree that I do not owe that. And do you agree that her Florida Q paperwork does not reflect the receipt of $1,789.58 paid to her attorney through the chapter 13 plan? A I agree that is true. Q Those sums total $23,371.68. Would you agree to that? A Yes, I do. Q Do you believe that the Florida judgment 1S incorrect by at least $23,371.68? A Yes, I do. Q Now, a couple of final questions. Did Ms. Dent file a child support complaint against you in 1992 and 1993 in Cumberland County Domestic Relations? A Yes, she did. GEIGER & LORIA REPORTING SERVICE 1-800-222-4577 . 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 . . 33 Q At anytime prior to June 5, 1998, did she ever discontinue that Cumberland County case at all? A Q Not that I know of. Before she discontinued the Cumberland County case, have you come to learn that she filed an action in Florida for child support? A Q Yes, she did. And at any point In time, have you ever agreed that Florida could exercise jurisdiction over the child support case? A No, I have not. Q Have you since come to learn that there is a law that requires you to file a written consent to allow the child support case to be transferred from Pennsylvania to Florida? A Q A Q Yes. Did you ever sign any such form? Never signed any such form. In reviewing your file at domestic relations, have you ever found any such form? A Never found any such form. MR. HOWELL: Well, that concludes GEIGER & LORIA REPORTING SERVICE 1-800-222-4577 . 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 . . 34 my questions for you, Mr. Bottorf. Let the record reflect that it is now 11:44 A.M. There has been no telephone calls from Ms. Dent to participate in this deposition. She did not return the telephone call that I just placed to her at 11:12 A.M., and her receptionist indicated in the presence of both the reporter plus my witness plus myself as officer of the court that she was, in fact, present in her office but was on the telephone at the time. I believe that concludes the deposition here, and I believe the court reporter has copies of all these exhibits. So that would conclude the deposition today. (The deposition was concluded at 11:45 A.M.) GEIGER & LORIA REPORTING SERVICE 1-800-222-4577 . . . 35 1 COUNTY OF LEBANON 2 COMMONWEALTH OF PENNSYLVANIA 3 I, Anthony J. Balshy, Reporter-Notary 4 Public, authorized to administer oaths within and 5 for the Commonwealth of Pennsylvania and take 6 depositions in the trial of causes, do hereby 7 certify that the foregoing is the testimony of 8 Richard Bottorf. 9 I further certify that before the 10 taking of said deposition, the witness was duly 11 sworn; that the questions and answers were taken 12 down stenographically by the said Anthony J. Balshy, 13 a Reporter-Notary Public, approved and agreed to, 14 and afterwards reduced to typewriting under the 15 direction of the said Reporter. 16 I further certify that the 17 proceedings and evidence are contained fully and 18 accurately in the notes taken by me on the within 19 deposition, and that this copy is a correct 20 transcript of the same. 21 In testimony 22 hereunto subscribed my hand 23 November, 2006. 24 NOTARIAl SEAL ANTHONY J BALSHV Notary Public 25 . GE G~~~~~~~I G SERVICE 1-800-222-4577 BOTTORF S PAMELA VS Plaintiff BOTTORF E RICHARD DR #: D20196 Defendant In the Court of Common Pleas of The 9th Judicial District of Pennsylvania, Cumberland County Branch Civil Action - Support Domestic Relations Section " ., Docket #: 595 S 92 19970512 DOCKET ENTRIES FROM FLAGLER COUNTY, FL A TNJ& 00f*Y fW)M REOOFI) In T~'U'tf ''''lo/llI~. I i... ~JnIO _ ., ..... ..1\018 ~ ~ _!oj ~ tll 0.__'" r..p~--J.yejf~ruJ, 0II;t; 01 QuIa O'I'i1lllll.O'" Q.....~Cfertfllc..r. ....u-~ ~.... .n......""" In J.,...."".? ltN_.LO ---- 19970512 19970512 19970512 19970512 199706 JO 19980211 19980211 1998021 I 19980211 1998021 I 19980225 199&0225 199&0225 19980323 19980323 19980611 1998061 I 19980611 19980611 19980617 19980617 >i" VERIFIED STATEMENT FOR REGISTRATION OF FOREIGN ORDERS OF SUPPORT, UNIFORM SUPPORT PETITION, CHILD SUPPORT TRANSMITTAL FROM FLAGLER CO" FLORIDA NOTICE OF REGISTRATION OF SUPPORT ORDER AFFIDAVIT OF SERVICE IN RE: SUPPORT ORDER OF COURT JAN. 29, 1998, AFTER CONSIDERATION OF THE ARGUMENT PRESENTED, WE DIRECT THAT THE FLORIDA ORDER BE REGISTERED IN P A BY THE COURT, GEORGE E HOFFER, PJ ORDER OF ATTACHMENT OF INCOME TO: B&L GLASS $98.15 PER WEEK BY THE COURT, GEORGE E HOFFER, PI GENERAL TESTIMONY FOR UIFSA, CHILD SUPPORT ENFORCEMENT TRANSMITTAL TRANSMITTED TO: FLAGLER CO., FL ORDER OF COURT JUNE 5,1998, SUPPORT ORDER TERMINATED EFFECTIVE 5113/98, ARREARAGE SET AT $8279.67. DEFT. TO PAY COSTS OF $21.50 BY 7/1/98. BY THE COURT, GEORGE E. HOFFER, PJ ORDER TO VACATE ATTACHMENT OF UNEMPLOYMENT BENEFITS BY THE COURT, GEORGE E HOFFER, PI Page: 1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY -SUPPORTS 595 SUPPORT Plaintiff - PAMELA S. BOTTORF vs Defendant - RICHARD E. BOTTORF, JR. FILED: June 18, 1992 COMPLAINT FOR SUPPORT FILED: 8/3/93 COMPLAINT A TAUI Ct:#'( ~ RE<X:ft) In T8IllImony IM~. I ~. \Ro _ *' __ .... ... Il6I!li r.;I Mid ~, lit '~'We.. Pa. -~'~ttJ12j ~Ti>; 01 CouIW ~ County -oe,:u, a.m" CItItI Cun_1Iu.d 00unIv 0llMn 'II!"~I ... MaMIIir .....". 19 92 PAMELA S. OOI'TORF , PLAINI'IFF vs. RICHARD E. oorroRF, JR. , DEFENDANT DR 20,196 IN THE COURI' OF ca.M)N PLEAS OF CUMBERLAND COUNI'Y, PENNSYLVANIA JX>MESTIC RELATIONS SECTION CIVIL ACfION - SUPPORl' 00. 595 OF 1992 TO THE HOooRABLE JUDGES OF SAID COURI': CCMPLAINI' FOR SUPPORl' 1. Plaintiff resides at 655 Lewisberry Road, New Cumberland, PA 2. Defendant resides at 108 Beach Cliff Drive, Carlisle, PA 3/24/90 3. (a) Plaintiff and Defendant were married on at Laroyne, PA 6-11-92 (b) Plaintiff and Defendant were separated on n/a (c) Plaintiff and Defendant were divorced on at 4. Plaintiff and Defendant are the parents of the following children: (a) Born of marriage WIFE AND ONE CHILD Narre Lindsay M. Bottorf (b) Born out of wedlock DID #140 fc,;;) 3 II. 0 0 n 0,0-. Birth Date Age __::./ ~t~o 1 _/_/- _/_/- _/_/- _/_/- Residence w/pltf _/_/- _/_/- _/~/- o c:o ,-,1: r- C" rr! ..., ! ~T_l r:: ;'~ rr1 Cl .. - co '0 ,_ n ,..) --q '" ~ ..... ~ ~ -...J ~r.l - (fJ 1~ 5. I:efendant has neglected the duty to support or sufficiently support the aforerrentioned person ( s} since 6. (a) Plaintiff is (not) receiving Public Assistance in the amJunt of $ per " for. the 'support of (b) Plaintiff is receiving additional incare in the amJunt of $ per fran , 7. A previous support order was entered against the I:efendant on in an action at (Court, Term, Docket Number) in the amJunt of $ for the support of per There are (no) arrearages in the amount of $ The order has (not) been tenninated. 8. Plaintiff last received support fran I:efendant in the amount of $ on WHEREFDRE, Plaintiff requests that an Order be entered against I:efendant and in favor of the plaintiff and the aforementioned child(ren) for reasonable support. I verify that the statements made in this Canplaint and attached Incorre and Expense Statement are true and correct. I understand that false statements herein are made subject to the penalties of 18 PA C.S. 4904 relating to unsworn falsification to authorities. Dated: !o- \~ -q'd C::> r Plaintif~Q~ \ (,,1 ~ .... f\OI'ICE -- '.' GU~ifelines for child and spousal support have been prepared by the Court of Q.) Canron ~eas and are available for inspection in the office of the D:::mestic Relations Section, 13 North Hanover Street, Carlisle, PA 17013. Additional infonmtion: ,J' 5. Defendant has neglected the duty to support or sufficiently support the afore.rrentioned person (s) since 6. (a) Plaintiff is (not) receiving Public Assistance in the arrount of $ per ,.,for. the 'support of (b) Plaintiff is receiving additional incare in the arrount of $ per fran . 7. A previous support order was entered against the Defendant on in an action at (Court, Tenn, Docket Number) in the arrount of $ per for the support of There are (no) arrearages in the amount of $ The order has (not) been terminated. 8. Plaintiff last received support fran Defendant in the amount of $ on WHEREFORE, Plaintiff requests that an Order be entered against Defendant and in favor of the plaintiff and the aforerrentioned child(ren) for reasonable support. I verify that the staterrents made in this Carplaint and attached Incare and Expense Staterrent are true and correct. I understand that false staterrents herein are made subject to the penalties of 18 PA C.S. 4904 relating to unsworn falsification to authorities. Dated: ~O - \~. -q'd, r .. c-=> Plaintif~Q~~ (",1 ~ a- rurICE -- '.' Gu1ttelines for child and spousal support have been prepared by the Court of .. - -=.u Ccmron ~eas and are available for inspection in the office of the Darestic Relations Section, 13 North Hanover Street, Carlisle, PA 17013. Additional infonnation: DR 20,196 PAMELA s. ~., I PLAIMI'IFF .. IN -WE <XX.JR;r<OP::<:x:M1:)N PLEAS OF CUMBERLAND COUNI'Y, PENNSYLVANIA vs. AUt; :1 2 'lOPN t93~ . I:a1ESTIC RELATIONS SOCTION CIVIL ACI'ION - SUPPORl' RICHARD E. BOTrORF FU'~ . t-O. 595 S OF 1992 C L'f R~t \:--:. :::-.-' ,:'4.":' - i: . ( c:a1PlAINr fUR SUPPORl' '1U THE HOOOAABLE JlJIX;ES OF SAID <X>UR1': 1. Plaintiff resides at Apt. #9, 17011 -; :"'t~ 2. Defendant resides at 108 Beechcliff Dr., Carlis~, PA. 17013 3. (a) Plaintiff and Defendant \\'ere married on 3-24-90 at Cumberland County (b) Plain1;iff and Defendant were separated on 7-19-93 (c) Plaintiff and Defendant were divorced on at 4. Plaintiffartd Defendant are the parents of the following children: (a) Born of marriage : Name Birth Date Age Residence 11; 241 90 -'-- with plaintiff Lindsay M. ( 197-72-7139) I I _1_1- _I_I- I I --- ( b) Born out of -wedlock I ! --- _1_1- _I_I _ DRO #140 ''!- _~~? CC',',' ('- 5., Defendant ,has neglected the duty to sUPPOrt or sufficiently support the '>.:~:t;~-, . aforerrentioned person ( s) since 6. (a) Plaintiff is (not) receiving Public Assistance in the arrount of $ per .for the support of (b) Plaintiff he:; receiving additional incare in the amount of $ r-- per fran 7. A previous support order was entered against the Defendant on in an action at (Court, Term, Docket Nu'rber) ill the amount of $ per for the support of There are (no) arrearages ill the arrount of ,$ The order has (not) been tenninated. 8. Plaintiff last received support fran Defendant in the amount of $ on WHEREFORE, Plaintiff requests that an Order be entered against Defendant and ~n favor of the plaintiff and the aforementioned child(ren) for reasonable support. I verify that the statements made in this Complaint and attached Income and Expense Staterrent are true and correct. I understand that false statements herein are made subject to the penalties of 18 PA C.S. 4904 relating to unsworn falsification to authorities. D3ted: ~ ~ ~L, -- Q~ PlaintiffQO~~~ f\OI'ICE Guidelines for child and spousal support have been ore pared by the Court of Common Pleas and are available for inspection in the office of the Domestic Relations Section, 13 North Hanover Street, Carlisle, PA 17013. Additional information: 5.. Defendant.hag..'neglected the:dutyto suppol:;"t or sufficiently support the ',., -'~, ': ~ ~~, ::...;tt;~"'. _,"'_.- ,,',\ aforementioned person ( s) since 6 . (a) Plaint iff is (not ) receiving Publij:: Assistance in the arrount of S per .for the'support of (b) Plaintiff :1...<; receiving additional incare in the amount of $ t-- per fran 7. A previous support order was entered against the cefendant on in an action at (Court, Tenn, Docket NlnOer) in the amount of .$ per for the support of There are (no) arrearages in the arrount ofS ' , . The order has (not) been terminated. 8. Plaintij:f .last;;re~i.yedsupport fran cefendant in the amount of .$ on WHEREFORE, Plaintiff requests that an Order be entered against Defendant and ~n favor of the plaintiff and the aforementioned child(ren) for reasonable support. I verify that the staterrents ffi3.de in this Cooplaint and attached Incare and Expense Statement are true and correct. I understand that false statements herein are made subject to the penalties of 18 PA C.S. 4904 relating to unsworn falsification to authorities. Dated: -.J ~ ~lo -. Q '2> PlaintiffQ~Sb~ N::YrICE Guidelines for child and spousal support have been orepared by the Court of Common Pleas and are available for inspection in the office of the Domestic Relations Section, 13 North Hanover Street, Carlisle, PA 17013. Additional information: . \ In the Court of Common Pleas of FLAGLER County of PeDJISylvanJa CHILD SUPPORT ENFORCEMENT TRANSMITIAL PLAINTIFF/ ~~~ PAMELA S. BOTTORF DEFENDANT/ f~'-' RICHARD E. BOTTORF JR TO: RESPONDING CENTRAL REGISTRY, COURT OR AGENCY (ADDRESS) ~~~. PO.~ 5:l~3q ..j~ ,?"'J... 3:~:l..C' FIPS CODE 1203500 (i) IV-D NON AFDC O IV-D AFDClIV.E FOSTER CARE o NON IV.D FROM: INITIATING CONTACT PERSON (AGENCY AND ADDRESS) DOMESTIC RELATIONS SECTION DOMESTIC RELATIONS SECTION P.O. BOX 320 CARLISLE PA 17013 FIPSCODE 4204U1 INITIATING CASElDOCKET NO. (PACSES CASE NO.) 754000020 595 S 92 COUNTY/STATE FLAGLER OTIIER REFERENCE NO. DR 20,196 RESPONDING CASEIDOCKET NO. 96-752-CA OTIIER REFERENCE NO. FlLESTAMP~ ~ ~ ~ C;. 0 v" '~'~.r:~~ FL ..-- ~~> ',.'.(\ A:\ j /.'C} ~t\ 1~ t..f> ~ ~ ~ ~ COUNTY/STATE F~Cc. FL DONNA K. RHOADS IF COLLECTION LOCATION IS NEW OR DIFFERENT LIST IN SECTION VI, PAGE I. ACTION REQUESTED 1. 0 LOCATION OF: A. 0 ABSENT PARENT B. 0 EMPLOYER AND VI AGES @ Please return the Acknowledgment attached c:.aF~A 7. 0 ENFORCEMENT OF EXISTING ORDER (~) C. 0 ASSETS D. 0 OmERINFORMATION TO ASSIST IN LOCATION W'::~A 2. 0 ESTABLISHMENT OF PATERNITY (8RI!M) t.ar~ 3. 0 ESTABLISHMENT OF ORDER~) FOR: A. 0 CHILD SUPPORT D. 0 MEDICAL COVERAGE B. 0 SPOUSAL SUPPORT E. 0 OTHER COSTS (e.g., Delivery (non lV-D only) Other Medical, Genetic Testing Costs, Attorney's Fees) UZF:.~ 8. 0 REGISTRATION OF FOREIGN SUPPORT ORDER~) 9. 0 CHANGE OF PAYEE (e.g., AFDC status change) 10.0 REDIRECT PAYMENT (e.g., Custodian has moved) 11. 0 ADMINISTRATIVE REVIEW FOR FEDERAL TAX OFFSET C. 0 UNREIMBURSED PUBUC ASSISTANCE (in lV-D cases, the amount must be reduced to a child support judgment.) 12.0 DOCUMENTATION OF INFORMATION (FEDERAL TAX OFFSET) A. 0 VERIFICATION OR PROVISION OF SSN ~ UI8A 4. '61 MODIFICATION OF EXISTING RESPONDING STATE ORDER ('WiRI!8'A) 5. 0 INCOME WITHHOLDING B. 0 VERIFICATION AND PROVISION OF SUPPORT ORDER AND ANY MODIFICATIONS C. 0 VERIFICATION OF ARREARS AND PROVISION OF CALCULATIONS 13. GY OTHER: UIFSA l..H~sll 6. 0 COLLECTION OF ARREARS (U1liD.. eR. tiEf'M) II. CASE SUMMARY (BACKGROUND OF THIS MATTER) DATE AND TYPE OF LAST COURT/ ADMINISTRATIVE ACTION DATE OF SUPPORT ORDER FEBRUARY 26, 1997 STATE &. COUNTY ISSUING ORDER FL FLAGLER COURT CASE NO. Cfh - 75;l -ell SUPPORT AMOUNT/FREQUENCY DATE OF LAST PAYMENT (Molllh. Day, Yr.) AMOUNT OF ARREARS PERIOD OF COMPUTATION (From/To) $428.64 /per month $ 7,734.84 01./01./95 to 03/04/98 OTHER BRIEF SUMMARY OF REQUEST: Complies with FSA-200 ServIce Type M Form UR-004 Worker ID 21501 :- In the Court of Common Pleas of FLAGLER County, Pennsylvania CHILD SUPPORT ENFORCEMENT TRANSMITTAL, PAGE 2 INITIATING CASE NO. 754000020 III. l. ABSENT PARENT INFORMATION FULL NAME AND ALIASES (First name, MI. Last Name) ADDRESS (Street, City, State, Zip) RICHARD E. BOTTORF JR EMPLOYER AND ADDRESS (Name, Street, City, State. Zip) 405 WREN CT MECHANICSBURG PA 17055-2094 HOME PHONE (Include Area Code) (717) 796-2407 WORK PHONE (Include Area Code) DATE AND PLACE OF BIRTII SEX 12/11/59 M LOCKHAVEN PA SOCIAL SECURITY NO. 168-48-,3931 o See Section VI III. 2. OTHER ABSENT PARENT (Where custodJau is not a parent) FULL NAME (First Name, MI, Last Name) ADDRESS (Street, City, Stale, Zip) EMPWYER AND ADDRESS (Name, Street, City, Stale, Zip) HOME PHONE (include Area Code) WORK PHONE (include Area Code) DATE AND PLACE OF BIRTH SEX SOCIAL SECURITY NO. IV. CUSTODIAN INFORMATION FULL NAME (First Name, MI, Last Name) ADDRESS (Street, City, Stale, Zip) PAMELA S. BOTTORF RE PAMELA BOTTORF 96 752 PO BOX 787 BUNNELL FL 32110-0787 EMPWYER AND ADDRESS (Name, Street. City, Stale, Zip) SOCIAL SECURITY NO. 174-46-5194 V. DEPENDENT CIDLDREN INFORMATION NAMES(S) (First Name, MI, Last Name) LINDSAY BOTTORF RACE SEX DATE OF BIR.TII SOCIAL SECURITY NO. RELATIONSHIP TO CUSTODIAN o 11/24/90 197 -72 -713 9 NATURAL CHILD o Additional Dependent Names Attached VI. ADDITIONAL CASE INFORMATION (NOTE OUTSTANDING PENDING ACTIONS, AMOUNTS REPORTED TO CREDIT BUREAUS, ETC.) ENCLOSED PLEASE FIND PHYSICAN'S INFORMATION REQUEST SIGNED BY MR. BOTTORF'S PHYSICAN. MR. BOTTORF IS REQUESTING A MODIFICATION OF THE CHILD SUPPORT ORDER. DEFENDANT SSN MULTIPLES VII,' AITACHMENTS (SUPPOR'l1NG OOCUMENTADON) o INITIATING STATE URESA LAW (3 copies)' o CERTIFICATE AND ORDER (3 copies) o UNIFORM SUPPORT PETITION (3 copies) (i) TESTIMONYI AFFIDAVIT (i) INCOME AND EXPENSE AFFIDAVIT o PAYMENT RECORD 0 Certified o AFFIDAVIT OF ARREARAGE o MARRIAGE CERTIFICATE o CONTINUED ON ATTACHED SHEET o PATERNITY AFFIDAVIT o OTHER DOCUMENTS RELATING TO PATERNITY o SUPPORT ORDER (3 copies) o DIVORCE DECREE o ASSIGNMENT OF RIGHTS o LOCATE DATA SHEET o PHOTOGRAPH OF ABSENT PARENT o OTHER ATTACHMENTS: (Specify in Section VI) 3-'I-t18 DATE Complies with FSA-200 Service Type M ~~a SIGNATURE AND AGENCY OF INITIATING CONTACT P Page 2 of2 "-- 1\ l - d.."" 0 - lod.~S:;- PHONE NUMBER Fonn UR-004 Worker ID 21501 PLAINTIFF'"~' PAMELA S. BOTTORF In the Court of Common Pleas of CUMBERr..AND County, Pennsylvania GENERAL TESTIMONY FOR BftfiBA U1 F'S A DEFENDANT! p~ RICHARD E. BOTTORF JR GP IV-D NON AFDC o IV-D AFDCIIV-E FOSTER CARE o NON IV-D INITIATING CASEIDOCKET NO. (pACSES CASE NO.) 754000020 595 S 92 COUNTY/STATE CUMBERLAND PA OrnER REFERENCE NO. DR 20,196 RESPONDING CASBIDOCKET NO. 96-752-CA OrnER REFERENCE NO. FILE STAMP COUNTY/STATE p~ Gt.. FL PAMELA S. BOTTORF (Name) being duly sworn, under penalties of perjury, testifies as follows: 1. NAME PAMELA S. BOTTORF 4. RELATIONSHIP TO DEFENDANT/RESPONDENT I. Personal Information 2. SOCIAL SECURITY NUMBER 174-46-5194 3. DATE OF BIRTH 01/13/60 o NEVER MARRIED TO EACH OrnER ~ MARRIED ON O~ /04 /QO IN DATE C"TlMP.F,RT.J>.Nn r.mlN'l'Y PJ>. COUNTY/STATE o MARRIED BY COMMON LAW FOR mE PERIOD TO DATES o DIVORCED ON IN COUNTY/STATE IX! SEPARATED ON IN COUNTY/STATE DATE DATE o LEGALLY SEPARATED ON IN COUNTY/STATE DATE o DIVORCE PENDING IN o OTHER COUNTY/STATE o SUPPORT ORDER ENTERED ON o NO SUPPORT ORDER DATE COURT AND LOCATION (DIVORCE AND SEPARATION): NOTE: ATIACH A CERTIFIED COPY OF THE DIVORCE DECREE OR SEPARATION AGREEMENT AND THE CURRENT SUPPORT ORDER. II. Dependent's Household Information 1. The following are the dependents for whom support is sought from the DefendantlRespondent: IS PATERNTY SUPPORT ORDER LNJNG WITII SOCIAL SECURITY AN ISSUE? ESTABLISHED? PETTITlONER? PULL NAME NUMBER SEX DATE OF BIRTH YES OR NO YES OR NO YES OR NO LINDSAY BOTTORF 197-72-7J.39 0 n/24/90 N YES NO o Additional Dependent's Household Information Attached. NOTE: A PATERNITY AFFIDAVIT IS REQUIRED FOR EACH CHILD NOT OF mE MARRIAGE WHOSE PATERNITY IS AT ISSUE. Complies with FSA-202 Service Type M Form UR-SOI Worker ID 21501 In the Court of Common Pleas of CUMBERLAND J'I County, Pennsylvania U T FS n GENERAL TESTIMONY FOR "~Jiil.4., PAGE 2 INITIATING CASE NO. 754000020 2. Does anyone else, not of the marriage, live in custodian's household? o YES (i) NO (If yes, provide information below.) SOURCE OF ,,"R' ""ME DATE OF BIR'nI ..." A T10NSHIP IN=R~R ~R~~T PER M~T11 $0 $0 $0 $0 $0 $0 lli. DefendantlRespondent Information l. FULL NAME (include nicknames, alias, etc.) RICHARD E. BOTTORF JR 2. RESIDENCE ADDRESS SOCIAL SECURITY NUMBER DATE OF BIRTH SEX 405 WREN CT 1.68-48-3931 12/11/59 M MECHANICSBURG PA 17055-2094 HOME MESSAGE PHONE WORK PHONE (717) 796-2407 3. EMPLOYER NAME AND ADDRESS OCCUPATION, TRADE OR PROFESSION ESTIMATED GROSS MONTHLY EARNINGS OTHER INCOME $0 $0 4. REAL OR PERSONAL PROPERTY 5. Physical description of Defendant/Respondent. (Attach photo if available.) RACE I HEIGHT WEIGHT I HAIR COLOR I EYE COLOR W 5 ft 09 inches lbs. BN GN SCARS, MARKS OR OTHER DISTINGUISHING FEATURES LEFT SHOULDER, TATOO CLOUD 6. PRESENT MARITAL STATUS NAME OF NEW SPOUSE OR NON-MARITAL PARTNER (i) MARRIED o LIVING WITH NON- MARITAL PARTNER IS CURRENT SPOUSE/PARTNER ESTIMATED GROSS o UNKNOWN EMPLOYED? MONTHLY EARNINGS o SINGLE o YES o NO 0 UNKNOWN $0 0 UNKNOWN NAME AND ADDRESS OF CURRENT SPOUSE'S EMPLOYER: 7. Is Defendant/Respondent responsible for dependents that are not living in the petitioner's household? <i) YES o NO 0 UNKNOWN (If yes, provide information below.) FULL NAME OF OTHER DEPENDENTS DATE OF RELATIONSHIP LIVING WITH: BIRTH BROOKE ELAINE BOTTORF 04/03/83 DAUGHTER WITH MOTHER I I Complies with FSA-202 Service Type M Page 2 of2 Form UR-50 I Worker ID 21501 In the Court of Common Pleas of CUMBERLAND l1 County, PeJmSylvanla UXPSn GENERAL TESTIMONY FOR I IIlWIiIoJ., PAGE 3 INITIATING CASE NO. 754000020 IV. Medical Insurance 1. Are dependents for whom support is sought presently covered by medical insurance: iii Yes 0 No 0 Unknown 2. Is spouse for whom support is being sought covered by medical insurance? If #1 and #2 are no, skip to #4. DYes 0 No 0 Unknown 3. Medical coverage is provided by: For dependent chifdren For spouse for wh~m support IS sougnt STATE MEDICAID o o [XJ o o o o o o o Policy Number: PLAINTIFF Plaintiff's Insurance Company: PLAINTIFF'S EMPLOYER Defendant's Insurance Company: DEFENDANT Policy Number: DEFENDANT'S EMPLOYER Other Insurance Company: Policy Number: The monthly cost paid by the Plaintiff for medical insurance for the Defendant's children only is: $ .00 (If medical insurance is provided by the Plaintiff or the Plaintit1"s employer, skip to number 5.) 4. The Plaintiff can purchase needed medical insurance at a monthly cost of: $ .00 5 . Were the children ever covered by medical insurance provided by the Defendant or his/her current employer? iii Yes 0 No 6. Do any of the Defendant's children have special needs or extraordinary medical expenses not covered by insurance? (If yes, explain.) o Yes iii No Complies with FSA- 202 Service Type M Form UR-S02 Worker ID 21501 In the Court of Common Pleas of CUMBERLAND County, Pennsylvania GENERAL TESTIMONY FOR URESA, PAGE 4 INITIATING CASE NO. 754000020 V. SUpport Order and Payment Information 1. Does a support order exist? (If no, skip to UR-504.) 2. Did the dependents reside with the plaintiff 0 YES during the entire period for which support is sought? 3. Describe current ordered support: (include the pertinent orders and modifications.) ORDERED SUPPORT AMOUNTS: DATE OF ORDER CURRENT AMOUNT PER MONTH/WEEKlETC. TOWARD ARREARAGE 02/26/97 $428.64 per month $.00 NAME AND ADDRESS OF COURT OR ADMINISTRATIVE AGENCY CUMBERLAND COUNTY COURT CUMBERLAND CO COURTHOUSE, 1 COURTHOUSE SQUARE, CARLISLE, PA. 17 (i) YES o NO o A'ITACH CERTIFIED COPIES OF ALL PERTINENT ORDERS THAT RELATE TO SUPPORT. NO IF NO, IDENTIFY PERIODS OF NON-RESIDENCY. PER MON11IIWEEKlETC. per month DATE OF ORDER CURRENT AMOUNT PER MONTH/WEEKlETC. TOWARD ARREARAGE $.00 per month $.00 NAME AND ADDRESS OF COURT OR ADMINISTRATIVE AGENCY PER MONTHIWEEKlETC. per month 4. Summary of Defendant arrearage o Adjudicated arrearage > DATE OF ORDER AMOUNT FROM (DATE) THRU (DATE) AFDC $ .00 NON-AFDC $ .00 TOTAL $ .00 COURT OR ADMINISTRATIVE AGENCY By order, issued by > FROM (DATE) THRU (DATE) o Includes interest, explain: AMOUNT AFDC $ .00 > NON-AFDC $ .00 TOTAL $ .00 AMOUNT AFDC $ .00 > NON-AFDC $ .00 TOTAL $ .00 o Final judgment by operation of law Total Arrearage AS OF (DATE) 5. Defendant made the last support payment of: , I AMOUNT > $ 0.00 DATE OF PAYMENT 6. Defendant's support payment history: A certified copy of court or o agency payment history is attached. (Skip to page 4b.) O Payment history provided on page 4a. o N.A.; responding state does not require. (Skip to page 4b.) FROM (YEAR) TO (YEAR) AGENCY WHICH PREPARED AUDIT/PAYMENT HISTORY: CUMBERLAND Complies with FSA-202 Service Type M Form UR-503 Worker ID 21501 In the Court of Common Pleas of CUMBERLAND County, Pennsylvania ~II GENERAL TESTIMONY FOR A., PAGE 6 INITIATING CASE NO. 754000020 C. Assets: ASSETS EXCEED A TOTAL OF $1500 ,(i) YES 0 NO (IF YES, COMPLETE THIS SECTION. IF NO, SKIP TO SECTION vm.) AMOUNT OR VALUE 1. CASH AND CHECKING ACCOUNTS 2. SAVINGS, CREDIT UNION, CERTIFICATES OF DEPOSIT 3. VALUE OF INVESTMENTS (I.E. STOCKS, BONDS, MUTUAL FUNDS, OTHER): UST $ .00 $ 00 $ 00 4. INSURANCE - CASH VALUE 5. REAL ESTATE - EQUITY: HOMESTEAD OTHER REAL ESTATE 6. MOTOR VEHICLES: AUTOMOBILES, MOTOR HOMES, BOATS. OTHER VEHICLES 7. OTHER PROPERTY: UST 8. TOTAL ASSETS VIII. Other Pertinent Information ::r l1J1.rt1!. oMer t:!:~p-en5es I ~+~ ~ a~ScJj\)\~ lrr5t.l~l1ve 010 4.nose ,~~ 7 ...\-h~ d.r-e. ~ l~~ "'~~d G\\-- ~S +\Tfl~. ~ IX. WAIVER OF FEES , petitioner is indigent and unable to pay the costs of these proceedings. All of the information and facts contained in this GENERAL TESTIMONY are true and correct to my best knowledge and belief. ~ ILf!?8 - IDATEI "R;~rd E, 'l)6ttor~ ""k fudU ..r'1.'PETmONER (NAME/TITLE) CA..{'etJo At.! t ~, DATE AGENCY REPRESENTATIVE (NAME/TITLE) SIGNATURE 3-Lf-q8 SWORN TO AND SIGNED BEFORE ME mIS DATE, COUNTY, STATE ~~co~ OFFICIAL AND TITLE -Deputy C$erk of Couml ~Id County COmmlsslon__ AIIt Mclncfay In J.-1uery 20 () 0 .- COMMISSION EXPIRES Complies with FSA-202 ServIce Type M Page 2 of2 Form UR-505 Worker ill 21501 ---- ----------- ----- -- ------ ------------------- ------------------------ ------------------------- , \ -' --~----------- -~-------- ----------- , \ \ ---~/-/~-~-~~--~-_/~ -~~--~~--~-~--~~~~- ~--~~~--~ ,----~ ------ . \ , \ /--~----~~ ~---~---~/~----~ ~ ------------+--~--~-~~-~------~-- _/---_/---~-~~.~~--~--~../... ,M~r. 19 '98 23:42 1111 Ph~si~ni WEIGHT LOSS Ctr TEL 717-761-2704 P. 1 f]'~ 0/} I.(~(..~ ~n the CQUl1 of Common J~JCIl1t of ClJMfJERI#AN,) County, Jl>enf!'J'lvanht U()'lI~;S'rlC IU~I,A l'I(}N~ 1'.(1. BOX .UII. t:AlU.lSl.l~, 1'.0\. 1'1113 Phone: (71'):40.~~Z~ Fa~: (7j7) 240-6248 " ! .,!II . , \,,' " ~ ~, ..1:1 ... MAllc.'H ~. ).9ge Member Name; ~XCHAA.ll l~. UOTTORF dR Docket Number: ~.~l~. !.; 92 PACSF.S Case Nl.Imbtr: "/!)40(1(')(I),0 Othel'St.a(c lD Number: ~ ftUlC'l AU C'tll1"C!IIpoadl'I('" IlIIlM u\('hldl' (ltl~ I'ACS"~~ ClI.t. NIIIIl!tI"" PU\,SICIAN'S INFORMA TIO~ REOUES): ~ TO HE COMN,ETEJ) HY AT'fENJ)JNO PHYSICIAN: . . ~.. / / 1,/'/;" 1/}~1 Physiclan's Name: C' l .-(..-1'(.....)'''- t/{./ LI' .~.o "( . . ........ n. ~--'. ",..'-.-." '-'-"'_"-"~'_>""""'__"'. .........:..::~..:~ '" _'_' 1'''. ~~~~"~\~j0~:;:;~}~~ribC;;:I~~:';:n>-jr an~ .". -".~.....,..., \, ~ .. ..,.-. .,....."+ . ."..._..-........~.~~ "....,,,.. -_..~ --'-'" ""--.. ,"," .... . .~" "'., , . .~~ ".. ,.......... . (t.) (d) (a)- ;;~te:~;r:, ;~aIOle"I;~;YZi(". :_ ___._.:~_'-: (b) Date of most rccellltreatmcnt.: .~.-!::.~:~!J..48_"._. .._., .~,.......L -;l ~ ~ Frequency of trca.!mems: .... t:i.. .~ c).. ,~-" ~'.:~(;::~,~:/"<.~~{..-._. ' .--....-.-t-...---- ,,.._ Medication: .._ '.~~{jl._..__... . .._....__.. ..,___ __". "'"._..__..~_"'_._....._..., The patient ha!; bt~fl continuously disabled (unable Ii) work) from: . , ;1 '~I; disab~~:.~;;;.lIe~;.;);~hle 1~:O:'~:'Jl e;"':~~::~'~:~~"7-.--- -a..-'/r..;~:.?:.:i2~:('\..<. _ . , ....... . ... __ .~ HEMARKS: ..._~. ."...... "_,,, ..w_, ,,,. ,_, ,__..... ,~ . .. . ,'. "....",.. ...... . ,..~.' ".' .._W'~'_""_ ....--.---. ':%-- . ......... ' ..... "". -.",.... "'." .-:) . . 7 " f)ate: ::....r ::::.~-r:~,:;-J, ..._' _'_'_"'. ...._ 1 hereby authorJ1.e my physielan 10 release the above fnfonnation 10 t.he CUHaIRLANO County })omcstlc RelaUons Seed ,.."... ...."....,., ,~~ ~.. n__ ,"...._..," ~ Sjg~,:~ . .11)i~ding.~.iC~j--~:u -fl') ~')~:~;~f(ir~ft..~ // . ~...:<:., ;:'1'1'( ;./ / / 1/-1 11 .,' . >71 ..7 'd. ,. "..... ~.7.~..~....,.. :~'"'/,L..-..t.- _....._..~ &. / 2~~___. ,. j...._.___ 7'.....;-. D..((~ ~ Form l.iNi>l ~ WI)rkt'I'14 :l1100 ~~r'(kc Typt.' 1>1 V. RICHARD E. BOTTORF, JR., Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DOMESTIC RELATIONS SECTION 595 SUPPORT 1992 DR 20,196 PAMELA S. BOTTORF, Plaintiff IN RE: SUPPORT ORDER OF COURT AND NOW, January 29, 1998, 3:20 p.m., after consideration of the argument presented, we direct that the Florida order be registered in Pennsylvania. By the Court, D.R.O. Michael R. Rundle, Esquire For D.R,O. Richard E. Bottorf, Jr., Defendant 405 Wren Court Mechonicsburg, Pa. 17055 Sheriff :mtf o 0'" :;;'=' ........0 c~, :,;"t. " ::: n, r= ....,;,., u~ tn =:;::'.::) ""'II"t; m ......, ~.. <),'0 .n"'" c' n.2! S~::~ :;;:...., "':;0 --<% r.i> .t:;. I'\,) I'\,) :i .. <..0 c:x::;) / _~ ._-S In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION PAMELA S. BOTTORF ) Docket Number 595 S 92 Plaintiff ) VS. ) P ACSES Case Number 754000020, RICHARD E. BOTI'ORF JR ) Defendant ) Other State ID Number 96-752-CA ORDER AND NOW, to wit on this 5TH DAY OF JUNE, 1998 IT IS HEREBY ORDERED that the support order in this case be 0 Vacated or 0 Suspended or (i) Terminated without prejudice, effective MAY 13, 1998 , due to: THE PLAINTIFFS REQUEST TO STOP SERVICES THOUGH FLORIDA AND PENNSYLVANIA. ARREARAGE SET AT $8279.67. DEFENDANT IS TO PAY THE COSTS IN THIS MATI'ER IN THE AMOUNT OF $21.50 BY JULY 1, 1998. ~ ~ ~ 0.. <) '<;:;~~.l :-:'11 ";:.;:", .,:':~\ ,<" --- ,.';,..t~ ; ','/< ';~% v:> $ & ~ .. ~ BY THE COURT: PRES. JUDGE DRO: lllcinda E. Sheaffer cc: Plaintiff Defendant Office of Child Support Enforcenent Service Type M Form OE-504 Worker ID 21100 ~.. . ~"'~"\NEY K.HOUGH, M.D., F~~.P. ".u.J.JS W. WILLARD, M.D., F.A.A.... .P. HUGH T. KNIGHT, M.D. LORRAINEW. McDONALD, M.S.N., C.R.N.P. . . M.JOAN, RICE, M.N., C.R.N.P. 49 BrookwooclAvenue. Carlisle, PA 17013-9126. 717243-8000. FAX 717245-3599 December 7, 1998 John C. Rodgers, M.D. 816 Belvedere Street Carlisle, PA 17013 Re: Richa~d Bottorf Dear J.R.: . . You'll be seeing Richard Bottorf on December 16, 1998 for an evaluation of back pain. I've enclosed a copy of my entire chart which indicates his past medical history, etc. The patient has incapacitating back pain where he in fact cannot even perform activities of daily. living. I've enclosed a copy of ~he patient's most recent IVIRI of his LS spine whiph ~ s~ows marked spinal stenosis L2-3. The patient has been treated conserva~ively civ~r the past year but now is to the point where he is totaUy disable~. The patierithas quite a bit of. inc~ntive to work but he is ~hysically una~leto. . ',I'm'sending him to you for you t~stronQIY consider surgical intervention for this patient'~ back pain. If you have any questions regarding him, please feel free to < . ...... - ,_ I . .' . . contact me. I look forward to hopefully some definitive treatment for his back". ' Yours truly, ~ . ~ . -~.. . . .. .' ~' . . , 'Rodne'y K.'Hough, M;D.' " .... . -. . . " .,', .RKH/b~'.'; ; ,: ",:.EnClosures '-:....... ~ ~ .: ", I .. ~un-~~-~ij w~u 1U:21 AM NORWEST FINANCIAL FAX NO. 717 76~.9386 P,Ol . ./~' CENTURION CUIlalty Company 206 Eiptb. st=l. Des MoIDes. Iowa 50309 TO: ClAIM DEPT. + AJistnINnt Gu/tM USE "NrrtATE INSURANCE ClAlM- SWIFTCHART 3.33 INSUReD BOttoar Ja.MR.IUCHARD E, 405 WEN CT MECBANICSBURG.PA .11055 BR. 611 ACe! NO. 15470432 IJ:~. ,'n '/~'3 \ q4\ TYPE Ala-c STATEMENT OF AmNDING PHYSICIAN .. (PIeaee answer aU Quel1ions) 1. Pa1Ient'.FuIlName~ ~rd f... J'r. Last First Middle 2. o..oribeOiagno.islOlsabiJity S~ 74re..)Jj~rde.r- I ChrCY');<..~.o R110 3. List all date. of treatment sin~ IlISt report ~J 3}q q J I plJ'x /9 9 4. I. patient disabled from performing hi_Jher normal occupation? yes'f:{J. No 0 6. I. pltient disabled from ~rforming any occupation or any work for oornp.~tion or profit? Yet lSD' No 0 If no, please list III rHUictioM 6. Oata patient able to ...turn 10 work ,'me. lP9Cific role.a. d,., pl.... ..tim.. 0 le.s that) 6 months 0 6012 mGn1h.,k( ewe Oate Lr> );13 J qq Physici.n's Signwre . 11llle 02It1 (CCt1 Add..... II ~ . Corh 'sl e.. I PI) J7Q/3 . Phone Number( 7/7 ) c:J<i3-g'eoo it unable to g~ Physici"n's Name thO USE p,s CONTINUOUS ClAIM FORM ONLY . . . ~ (.;:.....'. ,.,. ,- I ( ., ADDENDUM TO PSYCHIATRIC EVALUATION * RlCHA.RD BOTT9ll1i' SS# 161-48-3931 PldeDt Name 1111111_ Date or BIrdl XEYS'MNE Beadt PIlla DR. HOUf'dI Primary Care Pradicc (Medical) In discussion with Richard and his wife, they have mentioned ongoing custody issues with Richard's first wife. Careful review of Richard"s history as wen as current presentation reveals no signs indicative of aggression. assaultiveness. danger to self or others. At this point nothing would appear to indicate any difficulties or danger with him spending time with his daughter and there does not appear to be any need for special supervision. I hope this information is helpful. ~I8I'I1AL.. FOR PROFESSIONAL USE 0IIl. V THIS INFORMATION HA$ Bt!EN DISCLOSED TO YOU fIRCJII ReCORDll WHDE c()NIIIDRTIMJ1'V 18 PROTlCTED BY LAW. ~I REGUlATIONI LlMfTYOUR RIGHT TO MAd Att( PURTHER D1SCLOaURE 01' THIS ~ATION. JII!NIlBYLVANIA ~ SEIMCII.INC. . <tlD~TKSEENn~V2.1999 < W~.H..w~,~Q " . 1 ..,.t1 7.2.1119 Ohid at. RAllUnthaI. M.D. Dale DA TE RETURN; t~~;:;~~t:~j~~~~~}~:t~~ :. ~ '.~~~'f::;,. ..;> ;,~""'~\~,.,~~""~ ,~,.~~:,,;'!'~~:':':'h':'i. \ ?_~..~ ~.: ~ :'~,i ~..l:j - ~j;~.~~- :~~~~':;,~~:;:~.~~~:1:~;L;~f~ii~'I.~' ~~~~;~:~:~;: t. ~:~:;.r.: 0:'::;'" .~...'.\ (~;:i:~"/' ..)~" ~.'t \ :I~~~ . "',";'-' ...: ,ti:l)~.,:,...,~.:.r":;~':~'';''''':'f...~ "',1. ". .~~~~.~t~"...~;:.;~,.;. -'.', ,.'i,-, :-'!-.':};,:.:' ;\:. -: :,1 ~~:~~;~~,. f~"';:',~.~,.'r~. ~~:~"~'.~;'~~~;i.:;;t~i:~~~[~1<~;,' t.. t ,', "r~ J' :,-''>r. :;o..~.~I: .JJ:.....~~.tl ~:;-JI '~tl,:': \ 1,.:.... ." t~,:1 1..,tI;~i.,"'" '== ~:i"l; 1J..~~ ~ ..... ~ : ::..~r...:l'l\' 't. :.,',; _':.....i;-tj;I.~...':p;-..V)...a~..,.;:,;:.: ~.'" .t"'~:"1.,"i: ;1'~ "c. .:~....::~~..:\ ~1 PENNSYLVANIA COUNSEUNG SERVICES 700 eLA Y STREET CARUSLE, PA 17013 (711) 246-925$ cc: Allmll. HOUGH DtcTATED BUT HOT REVlEWED:.,XX DICTATED ANO REVEWID: _ tlollJ S3d QQI'TQR I.J,T' VV,f Tft: aT (lUT ...... 1"'1' II'... . . . Fi LE Pennsyha..1"Ui Co~1-~~eling Services - Carlisle 700 c,,~ 5C-~ ~!'\.-.:"It:: . (717) 245-9255 . pax; (717) 24.5-9198 C_-e3dol)'l'l Po M1Mbc, M.S.,cUn/c f}i,.~r:tDr Roy A. SmIth Jr., f>h~. !-=:.:::-= . lwl' lot tJa\1~ MaA.IiXt.Cllliw VfC'l-Prt$/dettl Pennsy vania CouolCling ($~QVJCt'JS -- H"'Rll/$1l1/IlC 4911 Lt"'~"1 Uno HarrltbUll< I'A m09 (717) m-9610 P..: (717) ('''-9loA(l LANC' A STIlI. ~ Main Sllttl 1\.., I'tlo..bll'&'l'A "'!(l (7171 S6(l.19OII P.., (717) 5f,o.I'U ...:U4NON Ie. N. I~fl<<",h AYt"l.t \..(b1OO1\ t'A 17046 (7l7) m.16s.' ~." (7m ~72-l166 II~A.I'INO 17>> I'f'"1....(1I1I11 WYNNIII"~ HUl.. rA 1\lli0ll ('10)(,711.7270 PI" ((,10) (,7" :lII2~ REAOINll t'll'Y RlI Wuhl"l'un _.. hl..)01 Ilndinllo rA IMI (&In) 47K-8MIl Fa.: (610) t7HMl IleNAJ$SAN(:t 701 Clot.\.,.., 51'('(1 ta.",,!\, I'A 17042 (7171 17H7U r..: (717) 77..:\40,4 'CIIUYUCILL Cf,IIN1'Y )(l5 No"h 1NI1....~ W I'Ioot JIt)UfiWdl..IIA l'1itnl (1'17) 62" I'M ,,~., (717) 12ft 2'tlI7 WUHllOltti . U5 Ctlty'I",,~ 11kt "'+d1&l1Iaburs.l'^ 17O!\5 (71 n 7'f.\'~'6.' 1'." (717) 79(,.146(, VORl< 26 Mounl 7.k'" It.",d Ylvk.I'^ 174l1i 17171 ~I(I.()91H ~.x: (7J 7) 1!.!~~~ rc, J.be." r""f"ny'" ^,,"...... ""'tI"'" 1'IKIO.m.{).~ August 1 8, 1999 TO WHOM IT MAY CONCERN: Richard Bottorf is a patient under my ~ ':~::q ~~: 72'r depression. As of his most recent visit on August 18. 1 ~.~ i'.: ::-:."":'uiJ-:s significantly depressed and has bccn unuble to work. Given his co-morbid seizure disorder, Rich1:-: ~ :~ ~ ferred to the Hershey Medical Center neuropsychology servic.e ro." ~~:im' :CC1~~g/follow-up. I hope you find this infonnation helpful. Sincerely. COwj~.~,P'O David M. Rosenthal, M,D. lame " . -'.: . ., ," . .' . - - . . "'R6DNEYJ{~ HOUGH;I\tn~;)"'.A~A.F~P.' , 'WILLIS w. WILL;\RD~ M.D:;F.A.A.F.P., ' , , ",ROBERTF. SIGUENZA,M~D. , , M.JOAN RICE, M.N.;C~R.N.P. " ,', FAMllSPRACTICE " , 49Brookwood;\venue · Carlisle, PA. 17013-9126 · ,(717) 243-8000. Fax (717) 243-3599 " -. , -' --.. ,- ',; - .. .", - .' " ; .... - .'. .' AuglJst 19,,19,99,' .' .~"': 1 'Judge Hoffer' ", , ' Cumberland CountYCourt~ouse' . : Fourth Floor, ' ' " Car'li~le, PA ,17013 ". Dear Judge Hoffer: I have 'seen Mr. Richard Bottorf in the office today following his experiences in your courtroom. While there he suffered a temporal lobe seizure. He ie being studied at Hershey and seeing a psychiatrist for a complex problem of major depression, general anxiety disorder, temporal lobe seizure disorder and cognitive disorfer. He has severe problems which a team of physicians are working hard to make some headway. I would like to prote~l the lack of decorum you exhibited in the courtroom toward my . patient and his w,ife': I find that unconscionable. If you desire further details, please e: ' , " I,et me, kno"Y with the permission ot the client. " ., ',>, " .. ,'~ ",~ ", WillisW. '~'i'lIard,'M.D. .'. ': ' ~ ". ~ PennState Geisinger . Health System Botulinum Toxin Treatment 717531 8697 Tel Barbara K. O'Connell. MO Cerebro>,.seular Disease 717531 1441 Tel Raymond K. Reichwein. MO Clinical Neurophysiology 717531 8697 Tel EEG. Evoked Potentials Paul H. McCabe. MD Timolhy A. Sullivan. I\.ID E:\IG. l'ier\'e Conduction Zachary Simmons, \1 D \lilinJ J. Kothari, DO Barbara K. O'Connell. \1 D Timothy A. Sullivan. MD Transerania' Doppler Anna 1\.1. Barrell. M D t:pilellSY Program 717531 5600 Tel Paul H. McCabe, MD Na,,,y \lichel, PA.C Cathy McNew. RN. MS Genera' Neurology 7175311441 Tel Barbara K. O'COImell, MD Richard B. Tenser. MO J\lo,'ement Disorders 717531 8697 Tel Barbara K. O'Connell, MD Multiple Sclero.i. Program 717531 1441 Tel Richard B. Tenser. MD Barbara K. O'Connell. MD Neuromuscular Program 7175311441 Tel Zachary Simmons. MD \lilind J. KOlhari, DO Tammy Murphy. RNC. as Neuropsychology Program 7175311441 Tel Paul J. Eslinger. PhD Claire V. Flaherty.Craig, PhD Neurorehabilitation Unit 7175317312 Tel Anna M, BarrelL MD Cognitive Rehabilitation 717531 1441 Tel Paul J. Eslinger. PhO Claire V. Flaherty.Craig. PhO Stroke Trials 71753 I 8692 Tel Raymond K. Reichwein, MD Section of Neurology Milton S. Hershey Medical Center M.C. H037 PO. Box 850 Hershey, P A 17033-0850 717531 8692 Tel 7175314694 Fax 7175311441 Appts 717 531 4950 Clinic Richard B. Tenser, MD Section Head RODNEY K. HOUGH, M.D. 49 BROOKWOOD AVE CARLISLE PA 17013 September 14, 1999 Dear Dr. Hough: RE: Bottorf, Richard E MSHMC #: 0985582 Richard Bottorf is a 39-year-old gentleman who returned to the Neuropsychology Clinic for further evaluation of his progressive memory loss and intermittent confusion. Upon review of recent records and history provided by him and his wife, it does appear that there are three main areas of current treatment epilepsy currently treated with Dilantin 700 mg q.d, and Neurontin 300 mg t.i.d. (for restless legs as well), sleep apnea currently treated with CPAP, and depression currently treated with Effexor 300 mg q.d. The patient is followed by Dr. Rosenthal of Pennsylvania Counseling Services as well as Dr. Todd Samuels of the Camp Hill Neurology Center. We completed neuropsychological testing on him in May and June 1999, finding generally normal range of test scores but with inconsistencies in attention-concentration and visual memory. At this time, the patient appears to have declined further in his daily functioning. He describes frequent confusion and short-term memory loss, along with restrictive range of affect and depression, and the experience of tremendous frustration with his current limitations. He describes that he is more tired even with recent treatment by CPAP, and wonders if he will ever improve. He was accompanied to the appointment with his wife today and she was very supportive of him. He is currently being evaluated by the Bureau of Disability Determination, and I have supported his disability at this time. Plan: Since we have a comprehensive baseline of cognitive testing on Mr. Bottorf, we will recheck several of his test scores now about four months later. In addition, we have begun working with him on cognitive exercises to help improve his daily problem solving and short- term memory. It may be that several of his cognitive complaints will not improve until there is optimal treatment of his epilepsy, depression, and sleep apnea, all of which can contribute to cognitive impairment. J will be back in touch with regard to further results. Sincerely, ?~ Clinical Neuropsychologist Professor Division of Neurology PJE/rem D: 09/14/99 T: 09/15/99 15:30 c: /Neurology ~-20-98THU 09:00 AM NORWEST-~F I NANC I AL FAX NO, 717 783 9388 P.01 (p1ljIJS ~S1 CENTURION Life Insurance Company 206 Elgbrh Street. Des Meints, Iowa 50309 TO: CLAIM DEPT. ~~ +- Alignment Guid. Us. "Initiate Insurance Claim" SWlFTTransaetion 3.33 INSURED BOTTORF JR,MR,RICBARD E. 08/20/98 405 WBEN C'I MECHANICSBURG,PA ,17055 ~R. 611 ACCT NO. 15470432 TYPE A/R-C FRAUD N011CE Any person who knowingly and with intent to defraud any insurance company or other person fit" a statement of claim containing any nurrerially false information or conceals. for the purpose of misleading, information concerning any fact mllterial thereto commita a fraudulent insurance act. which is a crime. CLAIM SUBMITTED STATEMENT OF ATT'ENDING PHYSICIAN 1. Patient's Full Name 2. ~sinee last report 4. Is patient disabled from performing his/her normal occupation? Yes 0 No 5. Is patient disabled from performing any occupation or work for compensation or profit? ~ Yes 1f no, please list all restrictions 3. o No 6. Date patient able to return to work specific release date, please estimate Date F-~I, - 91 Physieian' $ Signature Physician's Name if unable to give o ,t::- months O. over 12 months ,"'ANL ~:~lHl $~eAJb. L.L:bJ-F .m,D ' , Address Phone Number USE AS CONTINUOUS CLAIM FORM ONLY , ...A'I"........o6... NOV-24-88 TUE 03:36 PM NORWESTJlNANCIAL FAX NO. 717 761,9388 P.02 '- .~:,. .-' CENTURION Casualty Compauy 206 Eighth StIt:a, Des Moines. Iowa 50309 ro: CLAIM DEPT. ~ctr /~'/ "P ~ AlJrlntMnI Gum. USE "INmATE INSURANCE CLAIM" SWIFTCHART 3.33 INSURED BOTTORF JR.MR,RICBARD E. 11/11/98 405 WREN CT MECBANlCSBURG,PA ,17055 BR. 611 ACCT NO. 15470432 TYPE A/R-C CLAIM SUBMITTED STATEMENT OF AnEND'NG PHYSICIAN (Ple..e answer all questions) 1. Patient"s Full Name ~o-\4.eK"~ ~(c't\o.('d. Last First 2. Descrlbe~~~r~ity: n~t"~\~d d\~~ ~... r.., ~ Middle o..\.on~ \)..)i'\-'" 3. Ust all dates of 1Teetment since last "port 4. 1$ patienl disabled from performing hisfher normal occupation? ves'rfJ No 0 5. Is pati.nt d"",b1.d from perf""",.. any occu.ation o. ~ ~~~ coT..tion .. proOO V.. ~ No 0 If no. please list all r8snictions j,c:t\ol \4 Q\ ~ - ~J\ ~~U 8. on. pationt abl.,., ..1Um ,., worl< ~ ~ ........ ", .... opeoili. ..I.... d.... .1.... estimate 0 ,...lIo.n 6 m.nth. 0 S-I2 _ J., 2 ~ ' _. O..-t. _ \ ~ ... \ .. C\ ~ Physician's Signature PhY.ici8n'sNam.~\lA""'\ ~ l \..... ~~ ~ pnn or type Address --.Osth~c 1llSd~te of PA 87~ tAR CHURCH RD. Phone Number( _ ~MP t-IILL PA 17011 ,,03113 tcCCl USE AS CON'T1NUOUS CLAIM fORM ONLY \ \, -'l,Q \ -<; So ~;\ /' ~lfR-09-98 THU 11: 18 AM CUMS-CTY DRO FAX NO. 717-240 8248 I '4.1 l"1U~ P. 02/02 " I ~I 'T~} \. ~ ~ ~ :'/ . In the Coort or ~on\mon PI~as of CUMBERLAND County, Pennsylvania J)()MI~~"fl(; IU~f,A 1'fo:\'s r.o, 80X 3Z0. C..\kLISI.Jo:, "A. 110J;) Phone: (7 J '} %40-6125 Fa~: (7l7) 140-6248 KARCH 4, 1998 ft;1L/{)~ # 57 Member Name: RICHhRD E. &OTTORF JR Docket Number: S9~ s 92 PACSES Case Number: 754000020 Other State ID Number: PI~e 1I0lC'l AU tornspozulCll('(' lIJ~t Iud.. tbe 'ACSES CMI: ~IIlDbL". PHYSICIAN'S INFORM^ TIQ~ REQU~ TO BE COMPLETED BY Al-rENDJNG PHYSICIAN: Physician's Name: ~ ~ &Jtf 1./ /)1 ~ ....-- ~::t~'S s~k~lnjury (Detcribe complical~ons, if any) _ ~~ - r~W~.pJ (a) (b) (c) (d) Date of firsllrea,mem, ~~7---' --" Date of most recent lreatment: t::R /s- ~8 F~uency of treatments: d - 3 /?7rYt. ~ Medication: 7<-1/l The patient has been conlinuously disabled (unable to work) from~ " 57/r/'r through ~~ If ~1shOUld palient be abl. to return (. W~~7 ~re "'~"' limitations? REMARKS: s!gn~ I hereby authorize my physician (0 release the above Inronnation 10 tbe CUMIIDLAm) County Domestic Reladons Secti Date: c?/~~~ / ..J 11" / r8 / I Date Flnn\ EN.015 Worker ID 21100 Service Typt M -.... L.VClO JUt 01'36 Pl1 --71) , ; , NORWEsr F 1 HAAc 1 AL NOfWE':"', t f fr.~.. NO, 717 7110 9386 .... FINANCIAL "" .ik- W"l f rom: S&-..-t\I-L I: FAX Number. Om/?: 'oice: Time: ~erum Fax; !!.". of Pages (in addition 10 cover shiM Subject: P (.e ~ K C': II '" VI f.. (. Ctv,f. .." v... J d,., ...... J- r < t...., f. It ,--7' J- 9:S r~. - - y-t;".~~f~ ..r ~-<- If you do not ~. all of rhe pages as indicated, plosse rel6phone. Thank you. 230 01/98 - - P, 01 _ APR-28-8E rUE 01:36 PM _0 . NORWESt. FINANCIAL FAX NO. 717 7P~ 9386 P.02 CENTURION Casualty Company 206 Eighth Street, Des Moines, Iowa 50309 / .fo~ +'1 ~ TO: CLAIM DEPT. ~\ \ -\- Alignment Guide USE '"INJT1ATE INSURANCE ClAIM" SWIFTeHART 3.33 INSURED BOTtORF J~JMRtRICBARD E, 04/28/98 405 WEN CT ~CBANICSBuaGJPA ,17055 BR. 611 Ace! NO. 15470432 TYPE A/N-C CLAIH SUBMItTED STATEMENT OF ATTENDING PHYSICIAN 1. Patient's Full Name 2. Describe Diagnosis/Disability Middle t..t!1", I J,.,j - C Jt? ./' 1// '" ,;;L. 3. Ust all dates of treatment since last report _~S7Yc5: 4. Is patient disabled from performing hisfher normal occupation? Yc:;.g--' No 0 S. Is patient di$abled frorn performing any occupa~on or any work 1M compensation or profit? Ye~ No 0 If no, please Il$t all resuictions 6. Date patient able to retum to work ~ ,1./lr; ti10 'i^-- if unable to giv :te. plea. estimate.z less than 8 months 0 6 12 mon1h!f p over ~ mo~ths & _am'5S;.n,,"," ~ lS_~. ~ Physician's N~rno,-.r~.".-"'^_ C'()JI'! ~_. ?71- Pleas& pnnt or typ8i BEST POSSIBLE . Address cr;;>: Al?J at..'1/ C6t<~ cZ DUE TO ORIGINAL 09JbAJkr:NT" (J.~ ~(/ >A <~. Phono Number( 227') ro't' S- .Tero Date , 1a,. en"3 (CCC) USE AS CONTINUOUS ClAIM FORM ONLY So!d 8y: Pember, Form H-t'80 ~. , IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY - SUPPORTS 641 SUPPORT 19 84 COMMONWEALTH VS CHARGE: Non Support PROS: Tracey J. Bottorf VERDICT: Richard E. Bottorf FILED: 9/25/84 DISTRICT ATTORNEY COMMITMENT SHERIFF PAROLE FILING PAPERS. ETC. LYING IN EXPENSES SERVICE FEE CONTINUANCE TAKING RECOGNIZANCES POST AGE NOLLE PROS. BENCH W ARRENT COSTS PAID: Complaint, filed ORDER OF COURT AND NOW, this 25th day of September 1984, upon consideration of the above Agreement, IT IS HEREBY ORDERED AND DIRECTED that the Defendant pay through the Domestic Relations Office, the sum of $60.00 per week for and toward the support of: his child Brooke E., born 4/3/83. Defendant to maintain continuous medical insurance coverage on beneficiary of this order. The first payment shall be due on 9/25/84 and subsequent payments shall be due every week thereafter. The defendant shall pay the costs of $17.00, which sum includes the pro-rated Service Fee of $7.00, payable 90 days. ITE FURTHER ORDERED that the Defendant inform the Domestic Re1ations'Office of any change of address and/or employment in writing within ten days of such change. By the Court, George E. Hoffer, J. FILED: 9/25/84 ORDER OF ATTACHMENT OF WAGES, TO: Fry Communica tio ns $60 ,,--O..o_1l.eJ::.. week A nut ct:11"f ""'* RECJDHW In T.....lI!I1IltJ ~ \ Nfe UJ'C) .. .. bifid ... _ NI!Ii cI uk! O~l. ea.~ P8. ~~,if!;~b ad of 0aYItI ~~ c;I c......1i11 .... o.nlr ~leMI~i:1 C~...... ... ~ 1ft ..li/!IN1-....1A.' SALARY AND COMMISSIONS By the Court, George E. Hoffer, J. .r 'JaJJoH .~ afiJoa~ , :pno::> aql AS .ldwaluo::> JOJ palsTTaJ aq ol sT sse::> sql 'ATsATln::>ssuo::> psssTw aJe s~aaM OM:j. 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GORDON J TRACEY VS Plaintiff BOTTORF E RICHARD DR #: D11846 Defendant In the Court of Common Pleas of The 9th Judicial District of Pennsylvania, Cumberland County Branch Civil Action - Support Domestic Relations Section Docket #: 641 S 84 19960524 PETITION FOR CIVIL CONTEMPT A TAUt! 0CJfIY ~ N:<X.'R) In T~-.y ~WrI':;;';;, I ;'fllIlitl ..~ IiAIIIl '*It bMd ... it.. Net ei ~j CA.....1 .. C:a.;~ Pa. 11* rJ:;; dll~C~ ,;.; tA ----- .-/ OlIn 0If 0IMtI ewr$&lln~ ~~Q$c.na C\.~~i C~.... .... r~ 1n..'i1/!81'f 'IIi..lJ.) 19970815 19970815 19970815 19970815 19970815 19970815 19970815 19990819 19990823 19990823 19990823 19990823 19990823 19990823 19990823 19990823 19990823 19990823 19990823 19990823 19990823 ORDER OF COURT AUG. 11, 1997, THE SUPPORT ORDER IS SUSPENDED EFFECTIVE 5-15-97, DUE TO CERVICAL SPINE SURGERY, DEFENDANT UNABLE TO WORK AND HAS NO OTHER SOURCE OF INCOME. DEFENDANT TO REPORT ON A MONTHLY BASIS HIS MEDICAL CONDITION, AND ANY INCOME FROM ANY SOURCE. THE ORDER DATED 11-14-86, SHALL BE REACTIVATED WHEN DEFENDANT CONFIRMS HE IS ABLE TO WORK. BY THE COURT, GEORGE E. HOFFER, 1 PETITION FOR MODIFICATION (PL TF) ORDER JULY 13, 1999, THE PLTF'S PETITION FOR REINSTATEMENT OF THE ORDER IS DENIED, AS THE DEFT. HAS PROVIDED VERFICATION TO DRO THAT HE IS STILL DISABLED AND UNABLE TO PAY SUPPORT. BY THE COURT, GEORGE E. HOFFER, Pl ORDER OF COURT AUG. 19,1999, TESTIMONY HAVING BEEN TAKEN AS TO THE DEFT'S ABILITY OR INABILITY TO WORK BECAUSE OF A MEDICAL CONDITION, WE DO FIND THAT PAST MEDICAL CONDITION CONTINUES AND THAT AT THE PRESENT TIME HE HAS NO ABILITY TO PERFORM GAINFUL EMPLOYMENT. SHOULD THE DEFT. BE SUCCESSFUL IN HIS REQUEST FOR SOCIAL SECURITY DISABILITY INCOME, HE IS DIRECTLY TO IMMEDIATEL Y NOTIFY DRO OF THAT SITUATION. BY THE COURT, GEORGE E. HOFFER, Pl Page: I DR 11.846 r TRACEY 1. BOTTORF PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLVANIA VS DOMESTIC RELATIONS SECTION CIVIL ACTION - SUPPORT RICHARD E. BOTTORF. JR. DEFENDANT NO. 641 S 84 ORDER OF COURT AND NOW. this Illh day of August 1997. upon the consideration of the recommendation of the Domestic Relations OfticeL IT IS HEREBY ORDERED AND DIRECTED that the support order be suspended dfective May 15. 1997. due to cervical spine surgery. Defendant was unable to work and has no income from any other source. IT IS FURTHER ORDERED that defendant report on a monthly basis his medical condition. and any income from any source. The order dated 11/14/86. shall be reacitivated when ddendant continns he is able to work. This order shall become tinal ten days after the mailing of the notice of the entry of the order to the parties unless either party tiles a written demand with the Domestic Relations Section for a hearing de novo bdore the Court. BY THE COURT. J. DRO: Lucinda E. Sheatler cc: plaintiff defendant ~ c::: C? - w. ;-';",,':"') ~;".--l (.-) U) ... (..0 ---l I .r In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION TRACEY J. GORDON ) Docket Number 641 S 84 Plaintiff ) VS. ) P ACSES Case Number 320000076 RICHARD E. BOTTORF JR ) Defendant ) Other State ID Number DR 11846 Order AND NOW to wit, this July 13, 1999, it is hereby Ordered that: THE PLAINTIFF'S PETITION FOR REINSTATEMENT OF THE ORDER IS DENIED, AS THE DEFENDANT HAS PROVIDED VERIFICATION TO DRO THAT HE IS STILL DISABLED AND UNABLE TO PAY SUPPORT. ::~ c:;: ..'J r'....~,) C:.J c'~ BY THE COURT: IRO: Melissa S. Heckard ;C: Plaintiff & Defendant JUDGE Service Type M Form OE-520 Worker ID 21105 j I I .' . . TRACEY J. GORDON, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - SUPPORT DOMESTIC RELATIONS SECTION v. RICHARD E. BOTTORF, JR., Defendant NO. 641 SUPPORT 1984 DR 11,846 ORDER OF COURT . AND NOW, this 19th day of August, 1999, testimony having been taken as to the Defendant's. ability or inability to work because of a medical condition, we do find that past medical condition continues and that at the present time he has no ability to perform gainful employment. Should the Defendant be successful in his request for social security disability income, he is directed to immediately notify the Domestic Relations Office of that situation. By the Court, Michael R. Rundle, Esquire Special Counsel for DRO Richard E. Bottorf, Jr. 405 Wren Court Mechanicsburg, PA 17'055 Defendant, Pro se -;:"",.:3t t>..",... ;,;;-.',) Sheriff ..,.,<. ...."....- :srs , ! 11 IN THE MATTER OF: UNITED STATES BANKRUPTCY COURT MIDDLE DISTRICT PENNSYLVANIA ) ) ) ) ) ) ) ) -----------------------------------------------) RICHARD E BOTTORF JR 810 SHERWOOD ROAD NEW CUMBERLAND, PA 17070 DEBTOR ( S) PAGE 1 CHAPTER 13 CASE NO. 10501521 DATE FILED: 03/15/2005 DATE CONFIRMED: 08/30/2005 DATE CONCLUDED: 06/16/2006 CHAPTER 13 STANDING TRUSTEE'S FINAL REPORT CONFIRMED (CONV. TO CHAPTER 7) Pursuant to 11 U.S.C. Section 1302(b) (1) and Rule 2015(2), the Trustee has maintained detailed reports of receipts and disbursements which are as follows Claim Creditor's Name ----------------------------------------- -------------------------------------- Amount Allowed Paid to Date ----------------------------------------- -------------------------------------- Balance Due SECURED 101 GREEN TREE FINANCIAL CORP. 102 SOVEREIGN BANK 103 PENNSYLVANIA STATE BANK 104 PENNSYLVANIA STATE BANK PRIORITY 001 * JOHN P NEBLETT UNSECURED 201 WELLS FARGO FINANCIAL CONSUMER 202 WELLS FARGO FINANCIAL CONSUMER 203 DISCOVER 204 GREEN TREE FINANCIAL CORP. 205 WELLS FARGO FINANCIAL BANK 206 SOVEREIGN BANK 207 BOSCOV'S 208 BON TON 209 ECAST SETTLEMENT CORPORATION 210 ECAST SETTLEMENT CORPORATION 211 RESURGENT CAPITAL SERVICES 15,775.95 33,315.24 0.00 0.00 34,373.46 2,349.79 730.78 5,209.31 16,252.52 2,224.94 7,102.64 612.00 1,615.48 1,199.67 1,207.12 2,850.94 2,341.20 4,944.10 0.00 0.00 7,285.30 1,789.58 1,789.58 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 13,434.75 28,371.14 0.00 0.00 32,583.88 2,349.79 730.78 5,209.31 16,252.52 2,224.94 7,102.64 612.00 1,615.48 1,199.67 1,207.12 2,850.94 J * IN THE MATTER OF: UNITED STATES BANKRUPTCY COURT MIDDLE DISTRICT PENNSYLVANIA ) ) ) ) ) ) ) ) -----------------------------------------------) RICHARD E BOTTORF JR 810 SHERWOOD ROAD NEW CUMBERLAND, PA 17070 DEBTOR (S) PAGE 2 CHAPTER 13 CASE NO. 10501521 DATE FILED: 03/15/2005 DATE CONFIRMED: 08/30/2005 DATE CONCLUDED: 06/16/2006 CHAPTER 13 STANDING TRUSTEE'S FINAL REPORT CONFIRMED (CONV. TO CHAPTER 7) Pursuant to 11 U.S.C. Section 1302(b) (1) and Rule 2015(2), the Trustee has maintained detailed reports of receipts and disbursements which are as follows Claim Creditor's Name Amount Allowed ----------------------------------------- -------------------------------------- Paid to Date Balance Due ----------------------------------------- -------------------------------------- REFUND TO DEBTOR 999 **RICHARD E BOTTORF JR 0.00 DEBTOR ATTORNEY 000 G. PATRICK O'CONNOR, ESQUIRE 1,720.00 0.00 0.00 0.00 1,720.00 0.00 TOTAL RECEIPTS 11,220.00 -------------------------------------------------------------------------------- 1,720.00 DISBURSED 10,794.88 TRUSTEE FEES 425.12 CASH ON HAND 0.00 -------------------------------------------------------------------------------- IN THE MATTER OF: UNITED STATES BANKRUPTCY COURT MIDDLE DISTRICT PENNSYLVANIA ) ) ) ) ) ) ) ) -----------------------------------------------) RICHARD E BOTTORF JR 810 SHERWOOD ROAD NEW CUMBERLAND, PA 17070 DEBTOR ( S ) PAGE 3 CHAPTER 13 CASE NO. 10501521 DATE FILED: 03/15/2005 DATE CONFIRMED: 08/30/2005 DATE CONCLUDED: 06/16/2006 CHAPTER 13 STANDING TRUSTEE'S FINAL REPORT CONFIRMED (CONV. TO CHAPTER 7) J WHEREFORE, the Trustee prays that a Final Decree be entered discharging him/her as Trustee and releasing the Trustee and the Trustee's surety from any and all liability on account of the within proceedings, and closing the estate, and for such other relief as is just. Pursuant to FRBP 5009, I certify the case has been fully administered. /s/ CHARLES J. DEHART, III P.O. BOX 410 HUMMELSTOWN, PA 17036 PRINTED 06/16/06 Page lof2 i i ! I I I I I View Mail I ~..revious I. Next I P~il\ll~919);~earch Results . ;>~lyl . R~ly AU I ( Fo~i'dI"~.IIMove message to... ~ Subj: Date: From: To: (no 8ubject) 7/10120051:36:07 P.M. Eastern Standard Time RhE',l(3prS$ ~Iti,{~l~Z IGo To Page... Show Full Headers I Printer View I Add Sender To ddress Book I I Pam <pambciC@yahoo.com> I Attachments BBottorf@netscape.com Name Type Save ViE Note from Pam Message text/plain S~VE3 Sun 06/26/05 10:04 PM From: To: Subject: Date: Hi, I received your email. Thanks for the CIPy of your business card I'll hang onto it. I I i I'm going to send you a separate email with the directions to Steak & Shake. I The puppies look cute. Bet it's hard to ge~ rid of them - do you ge" attached to them? But then again I imagine hey are a lot of work so maybe you don't get too attached!! i Yes I had a good time at the movies today. bne of my gal friends frm work and I had a yummy Chinese lunch and wen~ to see Revenge of the S: for the second time. Saw it when it first c~e out and wanted to see again but I've been waiting for the crowds tp die down a bit. There 1 hardly anyone at the theater - most everyonel was going to see the new I :~witched or Batman movie. Popcorn and a gOFd movie - always makes fl excellent Sunday! I I I have to drop off a business colleague at t~e Orlando airport Friday evening and thought I'd spend Friday night ~ a friend's in Altamonte since I have to pick up the kiddo Saturday iorning. Saves me a long drive Friday night and Saturday morning. I I The thought occurred to me that it might be lnice if you, Brenda and I could meet for dinner Friday evening. It w~uld be a good chance for 1 to I talk and get a bit more comfortable with ea~h other. Plus Brenda and have not met. I'm thinking that if the thr e of us are comfortable w: each other then this will make things easie for Lindsay on Saturday. I I I . - - ",__"L.. ftl___t..___ .. I"tI ^^^,. .. Page 1 ofl Subj: (no subject) Date: 7/10120051:36:34 P.M. Eastern Standard Time From: Rheapl$$ To: IS6ItlY:37~I View Mail 1 F>r~viOU$.I. PAMBCI~..-Se.archRe$ult$ ..... ! ;'<R~)I~$'pJy All I .Fp~rd .'~.)~;IIMove message to... ...:z:ll I Show Full Headers I Printer View I Add Sender To ~ddress Book i IGo To Page... . From: To: Subject: Date: Pam <pambciC@yahoo.com> BBottorf@netscape.com Directions from Pam Sun 06/26/05 10:03 PM ~ame ~essa , i i Attachments Type Save Vie" e text/plain Save I Ric: Following is the link to go to the Steak & Shake website. I I http://\f.IWW. ste?kandshak(3. c()m/fincJ~ns/z:search,?sp Once you are on their website enter zip codei3270l & click the SEARCH button Then click the "MAP IT" button on the first search result (295 East . I Altamonte Drive location). It glves you a gpod map of the area. The steak ! and shake will appear as a red star. If you need a right of that the nearby area. hotel - you can click on "trav~l & transportation" to tJ map - then click on "hotels". ! It will show the ones in i Pam n1_..:I___..:J__. T..1.. 1'1 "tooe: A.........."".. n...l..I.... Dh"Ql-c.~ Page 1 of 1 Subj: (no subject) Date: 711012005 1 :35:27 P.M. Eastern Standard Time From: 8h~c:lpr$~ To: KAIJ::IY3Z57 From: Pam <pambciC@yahoo.com> To: bbottorf@netscape.com Subject: Note from Pam Date: Mon 06/27/05 05:26 AM Attachments Name Type Save ViE Message text/plain $~Y~ Ric & Brenda: I thought I would mention to you that since you're goil to come down this weekend - and the race is going on over in Daytona Beal you may want to call the track and see about getting tickets. My bos: called last week and purchased 4 tickets for some VIP clients and the: were still seats available - at that time. I'm not sure where the sea" were, they may have been back stretch, but the view from there is not bad. Thought I'd mention this. I'll check my email tonight when I get home from work. Pam "..- ......... .. How does that sound to you? Email me back when you have a chance. Pam .... .- -.....-- . Page 2 of2 ........ 'Y"IIo1l Page 1 of2 Subj: (no subject) Date: 7/10120051:34:18 P.M. Eastern standard Time From: Rh~~br~$ To:KA IIiY~7gI From: Pam <pambciC@yahoo.com> To: bbottorf@netscape.com SU~8~: VERY IMPORTANT NOTE FROM PAM!! Date: Tue 06/28/05 05:45 PM Attachments Name Type Save Vie Messa e textlplain$C3ve Very important - read all of this right away!! I am at work right now - it's about 5:30 and I'll be leaving around 6J We had some Underwriters come in from CNA today and most of the Commercial Dept employees are going to dinner with them tonight. Dinner is at 7J These things typically go long so I won't be able to call you tonight Email seems to work good forme. This is how I do most of my communicating these days both at work and in my personal life. Found out at work just a little while ago that my schedule has been changed for the coming week. My work plans change sometimes quite quickly - nature of the business these days and the type of accounts I work OJ I have to be in the Palm Coast office from Thursday 6-30 to Friday 7-8. Due to this change, and the account I've now got to work on, I won't be aJ to take my work colleague to the Orlando airport Friday evening. So, course, I won't be staying over in Altamonte Springs. Since I'm in Palm Coast we might as well set up everything for Palm Coast. I didn't think this is bad for you. I would think that you know the Palm Coast and surrounding area much better than Altamonte Springs. I DON'T KNOW YOUR TRAVEL PLANS YET BUT I WOULD RECOMMEND THAT YOU CAL: AND MAKE HOTEL RESERVATIONS RIGHT AWAY! ! !! Because of the races. As you probably know things fill up fast around here. I checked and the "Microtel Inn" in Palm Coast still had rooms. Their phone number is 386-445-9150. This hotel is only about 2 years old and is nice. Not the ..". Page 2 of2 Hyatt but nice. It's right over by the Cracker Barrel. You probably know that there is a "Sleep Inn" (phone is 386-446-8180) and also a "Hampton Inn" (phone is 386-446-4457) in town too. I'm not su: if they had room left or not. All three hotels are almost side by side' each other. So they are all in the same area and it's pretty conveni. to I95 and restaurants. Drop me an email then and let me know when you expect to come down an. where you'll be staying so I can reach you. I know you're waiting to leave until you receive your rx's. Yes I did enjoy the movie the other day. Revenge of the Sith was the new Star Wars movie that just came out. How's the puppies doing? Sold any this week? I'll check my email probably first thing in the morning. Pam WPiln,aC!tfau Tnlu 1'2 'lnne A_~":__ "'_1:___ nL__l_..__ Subj: (no subject) Date: 7/10120051:34:48 P.M. Eastern Standard Time From: Rb~~br,;;lS To: IS8IHY3757 From: To: Subject: Date: Pam <pambciC@yahoo.com> bbottorf@netscape.com Directions Mon 06127/0509:34 PM Go to the following website address: www.steaknshake.com 1. 2. 3. Click on locations Type in zip code 32701 Pick the first location at 295 E. Page 1 of! Attachments Name Type Save' Messa e text/plain $clY~ i Altamo1j1te Drive. Click on "map I 4. That takes you to a map of the area. i 5. If you need a hotel - look at the right bf the screen under "smar- view". Click on "travel & transportation" -!then click on "hotels". will show the ones in the nearby area. I I I I I I I I I I i I I i Pam Page 1 of 1 Subj: (no subject) . Date: 7110120051:33:27 P.M. Eastern Standard Time From: Rhe~br~~ To: IShIHY37pZ From: To: Subject: Date: Pam <pambcic@yahoo.com> bbottorf@netscape.com You there?? Wed 06/29/05 12:38 PM Attachments ame Type Save Viev essage textlplainSav~ Ric - did you get my email from late yesterd~y about weekend plans anI such? I I I can call you tonight after work but I'm not sure how late I'm worki) today. Working on a couple of very large 7-i accounts. I Let me know if you got the email and your Plfns. Pam I J I i I I t I I I i I I I I I [ i I I I I I I I I .....,. t _._..__~ T__1__ 1.... '"In^.c A_--=_... ^-.l:.I..__ n.....^^h-..n.... Page 1 of 1 Subj: (no subject) Date: 7110120051:32:52 P.M. Eastern Standard Time From: Rbea,\::)[$$ To:KATHY37_~ From: To: Subject: Date: Pam <pambciC@yahoo.com> bbottorf@netscape.com Hi back! Wed 06/29/05 06:22 PM Attachments Name Type Save V Messa e text/plain S~ye Ric - sounds like your life has gotten complicated. I think life thesf days is complicated for everyone - maybe just in different ways. Yes send me your plans. Did you get a hotel reservation made in town? I hope you did. I know things fill up fast but I think there were st. some rooms left. I meant to tell you that I would send photo's but I don't have a digi' camera. Glad to hear you've got some interest in the puppies. They are very Cl I would think that anyone would who call would know they have to have the money to buy one though. Are they that expensive? I think we paid about $500 for Mugsy as I recall. Well email back when you can and let me know your plans. Is Brenda planning to come along? Didn't know if she has to work or not. Actua: I don't even know what type of job she has. I'm going to run out for awhile and run some errands so my weekend is not tied up with doing "chores". I'll check my email when I get back. Pam 'llMn_r1~v Tnlv 11 '001:\ A""PPi~" Onli"",. Rh,.."hNq Page 1 of 1 Subj: (no subject) Date: 7/10120051:32:08 P.M. Eastern Standard Time From: RhE:latm;~ To: ~TH,(~lQZ View Mail ~revio.lJs..1 Next I P~~~FIS-_~earch Results h;R~Jy'l ~:!Ii~yAlJ ,1.,' F()~u~~.;IIMove message to... ..f.f Show Full Headers I Printer View I Add Sender To Address Book IGo To Page... - From: Pam <pambcic@yahoo.com> To: bbottorf@netscape.com Subject: Thursday A.M. Note Date: Thu 06/30/05 07:27 AM I received your note with your travel plans - thanks for keeping me updated. Attachments Name Type Save Vie Message text/plain Save Have a good drive down. It's been raining a lot this week but they Si it will ease up today/tomorrow. So how does dinner in Palm Coast tomorrow (Friday) sound? Say 5pm at the Sonny's b-b-q? It's right behind Steak & Shake. Chicken there is excellent and they have adult beverages if you want to have one. Plus the food is more like a sit down meal and it's not quite as crazy there. They aren't in as much of a hurry to "turn" tables around like a true fast food place. Anyway, let me know how this sounds to you. Email back if you can before you leave. I understand you'll be getting in very late so I will not call the on-star phone and wake you both. Pam -. .. - ---,. -. Page 1 of 1 Subj: (no sUbject) Date: 7/10120051:31:22 P.M. Eastern standard Time From: Rtt~<::lbr~$ To: ~ 1];-'y~75Z View Mail er~."iousJ Next leAMI?P~<?..S~arch Results f!iij)ly;IR~plyAJII.r::q~rn-t ;o~lIMove message to... 11 Show Full Headers I Printer View I Add Sender To Address Book lGo To Page... From: Pam <pambciC@yahoo.com> To: bbottorf@netscape.com Subject: Thursday 10pm Date: Thu 06/30/05 09:38 PM Attachments Name Type Save V Messa e textlplainSC3V~ Getting ready for bed. Been a very hectic week at the office and I'm just plain 01' tired. Hope Brenda is better? Send a note when you can and let me know how sl doing. Mid-next week is fine. In fact, it's probably better. The race fans w: all be gone and things will be back to normal around here. You might 1 able to actually get a room in town then for a reasonable amount - instead of a kings ransom. I'll talk with you in a day or two. Take care of Brenda. Pam "T....~........."..u l..lu 11 ')M.c;: AWll""";I'Q fl.nHn"" lU,,,.a'hI'QCO! Page 1 of2 Subj: (no subJect) Date: 7/1012005 1:29:34 P.M. Eastem Standard Time From: RI1~brE>.$ To:~ TtfY3]51 View Mail Previo~sl Next IP~PrII~flfi:..~Tarch Result$ RePlylu~~plyAlI.liIf9~~fJ~ ,;~IIMove message to... .:!::f Show Full Headers I Printer View I Add Sender To Address Book [Go To page: From: Pam <pambcic@yahoo.com> To: bbottorf@netscape.com Subject: Happy 4th! Date: Mon 07/04/0509:04 PM Attachments Name Type Save V Messa e text! lain Save Ric, I apologize for the delay in getting back to you. Since you did not come down this weekend, we made a spur of the moment decision and wen' to see some friends up in Jacksonville. Just got home a little while ago and I'm kinda tired but I read both your emails and I'll try to respond back to everything you mentioned or as: about. Here goes........ First, glad to hear that Brenda is doing better. Was it a migraine? Don't have any worries about coming to Flagler County. That warrant of no concern to me anymore and I believe it expired when the social security money started coming in. Things are different now so we decided to take you up on your request see us. That's why I called you. I started a new job a few months ago and I won't have any vacation or sick time that I can use until after Sept 1st. I work until 5-6 Monday-Friday. I can't drive all the way to Lake Buena Vista, do dinner and then drive back the same evening - and then be back at work the nl morning. On a good night it's a two hour drive and usually it's 2 1/: to 3 hours each way. That would get me home around midnight. If you COI ",y . " T__1__" "" "I\t\~ A _--:....._ 1"\.-1:...,-,,_ DhAn.....~~ Page 2 of2 drive to Palm Coast I could meet with you and Brenda almost any niqht the week. I'd still like to meet you and Brenda for dinner first as we previous. set up. There are some things that need to be discussed between the three of us first. Onto other things...... yes I think that the Visa card is a very nice id. on your part. stuff, etc. dinner. A teenage girl can never have enough clothes, makeup, hai: We can talk about this and the email thing when we meet : The computer stuff I really don't need but thank you for offering theI Our computer is about a year old and is pretty nice. I don't have a digital camera so the printer wouldn't be of any use to me. As regards Lindsay - she is very much into music, art, writing and computers. She's not really into sports and isn't a ~girly girlH eitJ She's just a normal, level headed fourteen year old going on twenty OJ She's a very smart girl, not a terror at all, and always does well in school. Lindsay is very aware of what's going on and she's not the least bit nervous although she is being just a bit cautious and she's the one w] asked that I meet with you and Brenda first. Email when you can. T" .. "" "^^~ A __ _~ __ t'"'\-1:__. DL_..-.1-.r"tl"I Page 1 of 1 Subj: (no 8UbJect) Date: 7/10120051:28:42 P.M. Eastern Standard Time From: RheablAS To: KA Tl:I~3757 View Mail ~$)(tJ PAMI:J.(?IC - Se~r~.h~es~.lts ~ePtyl. . Reply~J,51 J'd:;~d IMove message to... ~ Show Full Headers I Printer View I Add Sender To Address Book IGo To Page... , From: To: Subject: Date: Pam <pambciC@yahoo.com> bbottorf@netscape.com Tuesday Evening Tue 07/05/05 08: 11 PM Attachments Name Type Save Vie" Messa e textlplain$c:3VE3 Ric & Brenda - don't be concerned, the twice a day emails are not a problem. I check my personal email usually just once a day - in the evening about this time. Have a safe drive down. Do call Thursday and let me know you arrived I think that dinner Friday evening would be good. That will give you both time to rest up from the long drive. How about 5pm at Sonny's b-b-q in Palm Coast? PAMELA S. DENT flk/a PAMELA S. BOTTORF, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA vs. CIVIL ACTION - LAW NO. 06-4658 CIVIL RICHARD E. BOTTORF, Defendant IN RE: PETITION TO STRIKE FOREIGN JUDGMENT ORDER /"" AND NOW, this day of February, 2007, after hearing, the court finding the testimony of the plaintiff/respondent to be credible on issues having to do with the history of the Florida support order, the petition of the defendant, Richard E. Bottorf, to strike foreign judgment is DENIED. BY THE COURT, John P. Neblett, Esquire For the Plaintiff /1;[ Steven Howell, Esquire F or the Defendant ~.~ ~.O;Z.()J ~ :r1m Q [" . t' . JI ., (1-' I 'r"z v - (j.::1.J L"U 3ril ::10 3~:;I:!:!c.:,-Ci:nl:1