Technical Record-1 PDF

(
MAR 17 2014
TRANSCRIPT
NO.
151759-3
APPELLATE NO.
rti:coRI) ON
E2013-01528-COA-R3-CV
VOLUME I OF I
SUPPLEMENTAL # 2
APPEALED FROM
KNOX COUNTY CHANCERY COURT

AT KNOXVILLE, TENNESSEE
Michael W. Movers, CHANCELLOR

HOWARD G. HOGAN, CLERK and MASTER
IN TI IL CASE OF
Pamela Moritz Tula

PIainiiII/P.ppellant
VS.
Michael Peter Tula

1)cf endaiit/Appcllec
TO THE
COURT OF APPEALS
KNOXVILLE, TENNESSEE
JUDGMENT LOWER COURT

Paniela A Modtz appeals the final judgment/order of the Chancery Court of Knox County lilC(I
May 31, 2013 to the Court of Appeals
Pamela A. Moritz, Pro Sc, 108 South Ann Street, Lancaster, PA.. 17602, (717)381-0329
Phuntil I/Appcllaut
Kiniberlv R lavior, #018449, 135 S David Lane, Kiioxvihle, TN., 37922,(86J)693-8080

lklcudaiit/Appcllcc
FILED THIS
20
DAY OF
CLERK
COUwi ,
DEPUTY CLERK
NO.
TRANSMITTED THIS
DAY OF
20
011
PAMELA MORTIZ (formerly Tulay)

Plaintiff
Vs.
No. 151759-3
E2 Ol3-Cl528-COA-R3CV
MICHAEL PETER TULAY

Defendant
INDEX
SUPPLEMENTAL 1 2
DESCRIPTION
DATE
PAGE
Administrative Order to RedirecL Child

Support Payments
Oj,/O 2 ,J 20 C 6
32
Alias Summons Issued
03/0""/201C
87
Answer
05/20/2008
62
Answer
05/20// 200E
62
Cert fled Mail Receipt
11/14// 2001
Certified Mail Receipt
11/-14 //2001
Certified Mail Receipt
04/22/2013 112
Child Support Services
04/28,2006
3':
Child Sunporn Services
ILO/01/'200 7
/
41
07/24/2008
75
Flat
08/13/2008
7q
Injunction Issued and Executed
07/29/2008
7&
Issued Injunction
07/24/2008
Issued Injunction
08/13./2008
Letter Filed
12/20/2S07
46
Letter Filed
02/21/2013
97
Letter Filed - Motion for Default Judgment
01/31/2013
95
Mediation Order
12/21/200/
/1
Modified Order/Notice to NiLlihoid Income for

Child Support
10/01 /12007
Modified Order/NoLice to Njtoo..ricI .ncome for

Child Support
09/26/2006
80
Motion for Inclusion of Language Reflecting

Attorney's Leon with Exhibits
08/26/2002
19
Motion for Withdrawal of Counsel
05/05/2 CO 8
60
Motion to Compel Discovery and for Sanctions

and Notice to Appear for Hearing
07/21/20108
Motion to Permit Withdrawal of Counsel
06/17/2008
Non Resident Notice
05/17/2007
39
Notice
08/26/2002
24
Notice of Appearance
04/04/2008
Notice of Appearance - Faxed
03/31/2'008
57
Nonice of Atoorney's Lien
06/12/2002
Notice of Hearing
06/17// 2008
67
Notice of Trial Calendar Conflict
05/30/2008
65
Notice to Appear for Petition for Contempt,

for Modification, and for Injunctive Relief
07/19 /1 2010
91
Order
03/11/2014
Order of the Court
06/07/2002
16
Order Permittinq Withdrawal of Counsel
06/26/2008
68
Order/Notice to Withhold Income for Child

Support
04/28/2006
31
PLoof of Publication of Notice in Reading

Eagle
09/'18/2007
401
Report of the Mediator
06/04/2002
Show Cause Order
10/ 18/2 002
28
Subpoena Issued
03/20/2009
83 1
Subpoena Issued
03"'5/2009
Subpoena Issued
03/'30/2009
85
Summary of No--ices Prinred
11/14 /2C 07
44
Summary of Nor-ices Printed
12/04/2007
aa
Summary of Notices Printed
01/07/2008
49
Surrmary.o I Not ces Printed
02 /05/2 008
cc
Printed
03/31/20H8
58
051/2-3 /2008
64
06/19//2008
69
06/26/2008
70
03/06/2009
88
Summary of Polices Printed
04 /20 // 20 10
8$
ummaru of No
dc cc
34 :
05/10/2010
89
06/29/2010
90
00/16/2010
92
01/22/2013
94
01/31/2013
96
Summons Executed
Secretary of State
01/16/2008
50
Summons Executed
Secretary of State
05/1 6/2013
1(16
Summons Executed - Secretary of State
05/16/2013
110
Secretary of State
05/16/2013
115
Summons Executed
Summons Issued and Executed
07 / 31/2001
10/18/2002
29
12/10/2010
93
03/28/2013
98
03/28/2013
1)70
03/28/2013
102
04/10/2013
10 4
120
Supplemental Certificate of Appellate Record

Trial Notice
02 // 28/2002
Trial Notice
08/07/2002
18
Trial Notice
10 / 16 //0 0 2
26
Trial Norice
03/06/2003
27
Y COURT
AR 11 2014
PAMELA MORTIZ (formerly TULAY)
HOWARD G'. HOGAN
Petitioner,
vs.
No. 151759-3
MICHAEL PETER TULAY,
Respondent.
ORDER
The Clerk of the Court has exhaustively compared the contents of the Court's file
in the above-styled case. It appears that with the submission of the attached documents,
the Court of Appeals will have every document which exists in our files. The Court finds
that no documents remain within this file to further supplement the Appellate Record.
IT IS SO ORDERED.
Entered this \
day of
MICHAEL W. MOYERS
CHANCELLOR
cc:
Pamela Moritz, Pro Se

Michael Tulay, Pro Se
\ \5
IN THE CHANCERY COURT FOR KNOX COUNTY, TENNESSEE

PAMELA MORITZ TULAY,
)
)
Plaintiff,
vs.
No. 1I
/
Cl-

Defendant.
EI)
)
-
SUMMONS
To: MICHAEL PETER TULAY

216 SUGARWOOD DRIVE
KNOXVILLE, TN 37922
You are hereby summoned and required to serve upon James B.. LaPevor, plaintiffs
attorney, whose address is 1900 First Tennessee Plaza, 800 S. Gay Street, Knoxville, TN
37929, an answer to the complaint herewith served upon you within 30 days after service of
this summons and complaint upon you, exclusive of the day of service. If you fail to do so,
judgment by default can be taken against you for the relief demanded in the complaint.
Issued and tested this
day of
2001.
\11
Clerk>.
Deputy Clerk -
NOTICE
To the defendant:
MICHAEL PETER TULAY
Tennessee law provides a four thousand dollar ($4,000) personal property exemption
from execution or seizure to satisfy a judgment. J.fajudgment should be entered against you in
this action and you wish to claim property as exempt, you must file a written list, under oath,
of the items you wish to claim as exempt with the clerk of the court. The fist may be filed at
any time and may be changed by you thereafter as necessary, however, unless it is filed before
the judgment becomes final, it will not be effective as to any execution or garnishment issued
prior to the filing of the list. Certain items are automatically exempt by law and do not need to
be listed; these include items of necessary wearing apparel for yourself and your family and
trunks or other receptacles necessary to contain such apparel, family portraits, the family Bible,
and school books. Should any of these items be seized, you would have the right to recover
them. If you do not understand your exemption right or how to exercise it, you may wish to
seek the counsel of a lawyer.
To the process server Defendant MICHAEL PETER TULAY can be served at
216
SUGARWOOD DRIVE, KNOXVILLE, TENNESSEE, 37922.
I received this summons on the
day of
I hereby certify and return that onthe/ayof
____ 20.__.
,Z,9
2001,1:
tnred this summons and a complaint on defendant MICHAEL PETER TULAY in the
liowing manner.
[]failed to serve this summons within 30 days afts issuance because:
30 complete
Complete items 1, 2, and
item 4 if Restricted Deliver, desired.
Print your name and address on the reverse
so that we can return the card to you.
Attach this card to the back of the mailpiece,
or on the front if space permits.
A. Received by (Please Print
B. Date of Delivery
4t411&1 ( t)
t(11u) t21
C. SianareA
/)
1. Article Addressed to:
tWad
j4Lrzrrc/ 1
If YES,
.1
4. Restricted Delivery? (Extra Fee)

2. Article Number
(Transfer from service
PS Form
3811,
DAgent
Wr Addressee I
11 Yes
13 No
3. S rvice Type
M.I D Express Mail
0 Return Receipt for Merchandise
Registered
0 Insured Mail
0 C.O.D.
0 Yes
7001 0320 0005 7874 1601
March 2001
Domestic Return Receipt
JI
3(
102595-01-M-142
I Complete items 1,
13. Also complete
item 4 if Restricted t
,ery is desired.
I Print your name and address on the reverse
Received by (Please
'le-0y)
B. Date of Delivery
C. Signature
DAgent
D Addressee
D. Is delivery address different from item 1? 0 Yes

0 No
If YES, enter delivery address below:
j
ArUcle
Addressed
. to:
OgIto
4
'44f9J CIYK1
3.a ic elype
()J72
KgIstered Dnrcpt for Merchandise

0
13 Insured Mail
4. Restricted DeliveV4tra Fee)
2. Article Number
(flsnsfer from service lab"
PS Form
3811,
March 2001
7001 0320 0005 787

0 yes
1618
'73
..',
102595-01M-14241
C1Y COURT TRIAL NOTI

FILE COPY
02/28/02
CHANCERY COURT CLERK
400 MAIN STREET, CITY-COUNTY BLDG
KNOXVILLE, TN 37902
MORITZ
Vs.
TULAY MICHAEL PETER
TULAY PAMELA
CASE NO: 01-151159 PLEASE BE ADVISED THE

ABOVE STYLED CAUSE IS SET FOR TRIAL
AT 9:30 ON 6TH DAY OF SEPTEMBER 2002
CHANCELLOR CHAN SHARON BELL
NOTICES SENT TO
LAFEVOR JAMES R
MYNATT,
WILLIAM A.,
JR.
1:21
PAMELA M. TULA.Y,
Plaintiff
Docket No. 1517W--3
V.
Defendant
REPORT OF - THE MEDIATOR
Comes John K. Barber, Esquire, pursuant to Rule 31,

Tennessee Supreme Court Rules, and would respectfully report as
follows:
1.
Pursuant to the Order of this Court, the
parties participated in a mediation in my offices on May 10,

2002, and May 31, 2002. Present for the mediation were the
parties and their counsel.
2.
All parties negotiated in good faith, but the
resolution of this matter was unsuccessful by mediation.

3.
By agreement of the parties, the mediation
fees shall be paid by the parties and need not be charged as

court costs.
Respectfully submitted this
day of June, 2002.
JOHN K. BARBER
Pryor, Flynn, Priest & Barber
Two Centre Square, Suite 00
625 Gay Street
P. 0. Box 870
Knoxville, Tennessee 37901
(865) 522-4191
PRYOR, FLYNN
PRIEST & FIARBER
ATTORNEYS AT LAW
Suite 600
Two Centre Square
Me tor
P.O. Box 670

Knoxvihe, TN 37901
11
CERTIFICATE OF SERVICE
The undersigned hereby certifies that an exact copy
of this Report of the Mediator has been served upon the
following counsel of record by U.S. mail with sufficient
postage thereon to ensure the delivery of same:
James R. LaFevor
Nickle & LaFevor
1900 First Tennessee Plaza
800 S. Gay Street
William A. Nynatt, Jr.
Sheppeard & Swanson
616 W. Rill Avenue
P. 0. Box 2149
This the
day of June, 2002.
JOB2/K. HARBER, Mediator
PR'VR, FLYNN
PRIEST & HARBER
ATTORNEYS AT LAW
Suite 600
Two Centre Square
P.O. Box 870
Knoxville, TN 37901
N.

;:

Plaintiff,
J
)
VS.
0:
13
lV
No.
Noti of Entry Required
Defendant
PERMANENT PARENTING PLAN

This Permanent Parenting Plan with respect to the parenting of their child(ren) is
presented by PAMELA MORITZ TULAY, hereinafter referred to as Mother and by
MICHAEL PETER TULAY, hereinafter referred to as Father.
This Permanent Parenting Plan has been reached by:
[] Agreement [XI Mediation [J Other Alternative Dispute Resolution [ ] Court
Hearing on
I GENERAL INFORMATION
1.1 This parenting plan applies to the following children:
Birth Date
Primary Residence for purposes of
the child custody jurisdiction (T.C.A.
36.6-201) is with:
PETER MICHAEL TULAY
07129168_
[X] Mother
[]Fither
MONICA CLAIRE TULAY
10124189_
(]Father
[X] Mother
05/07199
[]Father
MARK KOLBE TULAY
[X] Mother
(]Father
[]Mother
Name
II. RESIDENTIAL SHARING SCHEDULE

These provisions set forth where the child(ren) shall reside each day of the year and
what contact the child(ren) shall have with each parent.
2.1 Pro-School Schedule
( ] There are no children of pre-school age.
( ] Prior to enrollment in school, the chlld(ren) shall primarily reside with
[X] Mother [ I Father, except for the following days and times when the
child(ren) will reside with or be with the other parent:
From: _5:00 PM ON FRIDAY_ to _8:00 PM ON SUNDAY________
day/time
day/time
( ] every week [X] every other week []other__________________________
and from: _5:00 PM ON FRIDAY to 10:00 AM ON SATURDAY alternate weekends
day/time
day/time
(]every week [xl every other week [X] other the pro-school child will go with
his older brother and sister.
2.2 School Schedule
Upon enrollment in school, the child(ren) shall primarily reside with (X] Mother
[ ] Father, except for the following days and times when the child(ren) will reside
with or be with the other parent:
From: _FRIDAY AT 5:00 PM
SUNDAY AT 8:00 PM________
day/time
day/time
400
( I every week (XI every other week (] other__________________________

to _SATURDAY AT 10:00 AM on
and from: _FRIDAY AT 5:00 PM
alternate weekends
day/time
day/time
(]every week [X] every other week []other_________________________
] The school schedule will start when each child begins:
(]kindergarten (]first grade (X] other children have been and are home
schooled by Pamela Tulay, so this schedule will be started now.
2.3 Schedule for Winter/Christmas Vacation (if applicable)
The child(ren) shall reside with the [X] Mother [ ] Father during winter vacation
except for the following days and times when the child(ren) will reside with or be
with the other parent:_FROM 10:00 AM. ON CHRISTMAS DAY (DECEMBER 25Th)
TO 7:00 PM ON JANUARY 1 3T EVERY YEAR.
2.4 Schedule for Spring Vacation
The child(ren) shall reside with the (X] Mother ( ] Father during spring vacation
except for the following days and times when the child(ren) will reside with or be
with the other parent:_FROM FRIDAY AT 5:00 PM ON MEMORIAL DAY WEEKEND
TO 7:00 PM THE FOLLOWING MONDAY EVERY YEAR
2.5 Summer Schedule
Upon completion of the school year, the child(ren) shall reside with (XJ Mother
()Father, except for the following days and times when the child(ren) will reside
with or be with the other parent:
[X] Same as school year schedule (]Other____________________________
2.6 Vacation with Parents
(I Does not apply.
(X] Schedule for vacation with parents as follows: CHILDREN WILL RESIDE
WITH FATHER FOR TWO (2) SEVEN DAY PERIODS AS DETERMINED PRIOR TO
MAY 1. MOTHER SHALL ALSO HAVE THE RIGHT FOR A THREE WEEK PERIOD
OF EXCLUSIVE TIME FOR SUMMER VACATION TO BE CHOSEN BY HER.
2.7 Schedule for Holidays and Other Special Occasions

The residential schedule for the child(ren) for the Holidays listed below is as
follows: (specify year)
With Mother
(even, odd or every)
THANKSGIVING .EVEN
MOTHER'S DAY .EVERY

FATHER'S DAY
With Father
(even, odd or every)
__ODD_______
(THANKSGMNG EVE FROM
5:00 PM TO THURSDAY AT
7:00 PM)
EVERY
(] Holidays which fall on a Friday or a Monday shall include Saturday and

Sunday. [JOther
2.8 Priorities Under the Residential Schedule
Defined Holiday, vacation and other periods above override the general
rotation of shared parenting.
2.911esttictions
(XJ Does not apply because there are no limiting factors in Section VI below.
10
[] The [ ] Father's [ ] Mother's residential time with the child(ren) shall be

limited because there are limiting factors in Section VI. The following
restrictions shall apply when the child(ren) spend time with this parent:
] There are limiting factors in Section VI, but there are no restrictions on
Father's ( ] Mother's residential time with the children for the following
reasons:
2.10 Transportation Arrangements

Transportation arrangements for the child(ren), other than costs,
between parents shall be as follows: ALL TRANSPORTATION WILL BE
BY THE FATHER EXCEPT IN RARE INSTANCES AND WHEN OTHER
ARRANGEMENTS ARE MADE 48 HOURS PRIOR TO VISITATION.
2.11 Designation of Custodian

The child(ren) named in this parenting plan are scheduled to reside the
majority of the time with the [X] Mother []Father. This parent is designated
the custodian of the child(ren) solely for purposes of all other state and federal
statutes which require a designation or determination of custody. This
designation shall not affect either parent's rights and responsibilities under
this parenting plan.
2.12 Other
Ill. DECISION MAKING

3.1 DAY TODAY DECISIONS
Each parent shall make decisions regarding the day-to-day care and control of
each child while the child is residing with that parent. Regardless of the
allocation of decision making in this parenting plan, either parent may make
emergency decisions affecting the health or safety of the children.
3.2 MAJOR DECISIONS
Major decisions regarding each child shall be made as follows:
Education decisions
(X] joint
(1 mother [] father
Non-emergency health care
(Xj mother []father
[]joint
Religious upbringing
(]mother []father
[X] joint
mother (J father
[]joint
(Jmother []father
[]joint
mother [] father
[]joint
In case the parties are unable to agree on joint decisions, mother's
decision will take precedent
because mother has primary
responsibility of the day to day
care and these are part of her
primary duties.
3.3 Restrictions in Decision-Making
(X] Does not apply because there are no limiting factors in Section VI.
(] Sole decision-making shall be decreed to the [ ] Mother [3 Father for the
11
following reasons:
[]A limitation on the other parent's decision-making authority is mandated by

T.C.A.36-6-406. (See Section VI.)
(] Both parents are opposed to mutual decision-making
(J One parent is opposed to mutual decision-making, and such opposition is
reasonably based on the following criteria:
( ] The existence of a limitation under T.C.A. 36-6406;
[ ] The history of participation of each parent in decision-making in
each of the areas in T.C.A. 36-6404;
(] The parent's ability and desire to cooperate with one another in
decision-making in each of the areas of T.C.A. 36-6404; and
[ ] The parents' geographic proximity to one another, to the extent that
it affects their ability to make timely mutual decisions.
(] There are limiting factors In Section VI, but there are no restrictions on
mutual decision-making for the following reasons:_______________________
IV. DISPUTE RESOLUTION

4.1 Dispute Resolution
(] No dispute resolution process, except court action, shall be ordered because
[]a limiting factor under T.C.A. 36-6406 applies or (]
[X] Disputes between the parties, other than child support disputes, shall be
submitted to:
(] Counseling by
. or.
or,
(X] Mediation by DR. JOHN KANDILAKIS
(] Arbitration by____________________________________
4.2 Costs
The cost of the Section 4.1 process shall be allocated between the parties as
follows:
[X] ______% Mother
% Father
(X] Based on each party's proportional share of income as defined
under the child support guidelines.
(] As determined in the dispute resolution process.
4.3. Notification
[X] The counseling, mediation or arbitration process shall be commenced by
notifying the other party by:
(] Mail []Certified Mall [X] Other TELEPHONE, FOLLOWED BY
MAIL, IF NECESSARY______________
4.4 Process
(X] In the dispute resolution process:
(a.) Preference shall be given to carrying out this Parenting Plan.
(b.) Unless an emergency exists, the parents shall use the designated
process to resolve disputes relating to Implementation of the plan,
except those related to financial support.
(c.) A written record shall be prepared of any agreement reached in
counseling or mediation and of each arbitration award and shall be
provided to each party.
(d.) If the court finds that a parent has used or frustrated the dispute
resolution process without good reason, the court shall award
attorney's fees and financial sanctions to the other parent
(e.) The parties have the right to review from the dispute resolution process
to the Chancery Court.
12
V. CHILD SUPPORT
5.1 Financial Support
[X] The (] Mother (XJ Father will pay child support in the amount of $3,900 per
month or $1,800.00 per BI-WEEKLY PAY PERIOD beginning _NOVEMBER 1, 2001.
FATHER WILL PAY CHILD SUPPORT BY PERSONAL CHECK UNTIL PAYROLL
EAJ
O1
S(
DIRECT DEPOSIT TO SUNTRUST BANK, ACCOUNT NO. 547036183 TAKES
EFFECT.
[X] The payer of child support shall make the payments set forth above directly
Mother's home with children.
to the other parent by mail or delivery at
[] The payer of child support shall make the payments set forth above by wage
assignment together with a 5% fee for a total of $______ per____________
beginning
(X] The payer of child support and the payer's attorney, if any, affirm that this
amount conforms to the Tennessee Child Support Guidelines.
(] The payer of child support and the payer's attorney, if any, affirm that this
amount of child support does not conform to the Tennessee Child Support
Guidelines, but it is in the best interest of the child(ren) because
and should nevertheless be approved by the Court because

The amount payable under the Guidelines would be: $_________________
[X] A wage assignment shall issue by separate order presented together with
the filing of this plan to SEQUOIA CONSULTING GROUP, the employer of the
payer of child support, whose address is 111 WASHINGTON STREET,
PLAINSV1LLE, MA 02762. The payer's social security number is 167-44-5376.
(XJ Other provisions for financial support: FATHER WILL PAY SUPPORT ON
ANY ADDITIONAL INCOME AT 41% OF THE AFTER TAX SUMS AS REQUIRED BY
TENNESSEE LAW.
[X] The parties affirmatively acknowledge that no action by either or both of
them will be effective to reduce child support after the due date of each payment.
The parties further understand that Court approval must be obtained before child
support can be reduced or modified, unless such payments are automatically
reduced or terminated under the terms of this parenting plan.
5.2 Tax Deduction
(] The ( ] Mother (X] Father will receive the tax deduction for the child(ren).
Each party shall provide to the other, by or before April 15 of every year, a copy of
their respective W-2 form or a copy of the first TWO pages of their tax return.
(X] Other provisions regarding tax deduction:
ST
The obligor [FATHER] shall report annually on the _30TH day of _APRIL._..
to the obligee [MOTHER], and the Department of Human Services or its contractor
in Title IV-D Cases, on a form provided by the Court, the obligor's income as
defined by the child support guidelines and related provisions contained in Title
36, Chapter 5.
5.3 Health Insurance
[ X ] The (1 Mother [X] Father shall maintain medical/hospital insurance on the
minor child(ren) and he shall provide proof of continuing coverage upon demand,
but in any event annually.
(X] Uncovered medicals, including deductibles, if any, will be
(X] borne by [] Mother [X] Father
[ ] divided equally by the parties
] shared as follows:______________________________________
13
5.4 Life Insurance

The (1 Mother (X] Father shall insure his own life in the minimum amount of
$100,000.00, whole or term, which may not decrease in face amount during the
minority of any child. The policy shall name the minor child(ren) as primary
beneficiaries of the coverage required by the Court. The choice of the secondary
beneficiary(ies) is up to the policy owner(s).
[ X ] Other provisions regarding life insurance: FATHER'S SAVINGS WILL BE
NOTED AS PAY ON DEATH ACCOUNTS FOR THE CHILDREN IN EQUAL SHARES
UNTIL HE REMARRIES.
5.5 Dental/Orthodontic care
The [ ] Mother [ ] Father will maintain L ] dental (] and orthodontic insurance
on the minor child(ren). Uncovered expenses will be borne by () Mother
(X] Father (1 divided equally by the parties.
[X] Other provisions for dental/orthodontic care: NO DENTAL INSURANCE
HAS BEEN MAINTAINED IN THE PAST; HOWEVER, IF FATHER CHOOSES, HE
MAY COVER THE CHILDREN FOR DENTALJORTHODONTIC CARE AT HIS
EXPENSE TO REDUCE THE COST TO HIMSELF.
Vi. BASIS FOR RESTRICTION
6.1 Restrictions due to Parental Conduct (T.C.A. 36.6-406)

[X] Does not apply
Mutual decision-making and designation of a dispute resolution process other
than court action shall NOT be required because (] Mother (] Father
has engaged in:

(] Willful abandonment that continues for an extended period of time or
substantial refusal to perform parenting responsibilities.
(] Physical, sexual, or a pattern of emotional abuse of a child or of another
person living with that child.
[J A history of acts of domestic violence as defined in T.C.A. 36-3-601 or an
assault or sexual assault which caused serious bodily injury or the fear of such
injury.
(] Other.
VII. STANDARD PARENTING ORDERS

Pursuant to T.C.A. 36-6-101 both parents are entitled to the following
rights:
1.
Unimpeded telephone conversations with the child(ren) at least
twice each week at reasonable times and for a reasonable
duration;
2.
Sending mail to the child(ren) which the other parent will not open
and will not censor;
3.
Receiving notice and relevant information as soon as practical
(but not more than 24 hours) in the event of hospitalization, major
illness, or death of the child(ren);
4.
Receiving, directly from the school, copies of the child(ren)'s
report cards, attendance records, teachers' names, class
schedules, standardized test scores, and other records which are
customarily made available to parents. A written request must be
made to the school with a current mailing address and payment
must be made for the reasonable cost of duplicating and mailing
these records;
S.
Receiving, directly from the child(ren)'s physician and other health
care providers, copies of the child(ren)'s medical records. A
written request must be made to the health care provider with a
current mailing address and payment must be made for the
14
reasonable cost of duplicating and mailing these records;

S. To be free of derogatory remarks made about one parent and his
or her family by the other parent to the child(ren) or in the
child(ren)'s presence.
To be given at least 48 hours notice, whenever possible, of all
7.
extracurricular activities and the opportunity to participate or
observe, including but not limited to, the following: (a) school
activities; (b)church activities; and (C) other activities as to which
parental participation or observation would be appropriate;
To receive from the other parent, in the event the other parent
8.
leaves the state with the minor child for more than two days, an
itinerary including telephone numbers for use in the event of an
emergency; and,
9.
Of access and participation in education, including the right of
access to the minor child for lunch and other activities, on the
same basis that is provided to all parents, provided the
participation or access is reasonable and does not interfere with
day-to-day operations or with the child's educational performance.
VIII. OTHER PROVISIONS
8.1 Violations
Violations of residential provisions of this order with actual knowledge of its
terms are punishable by contempt of court and may be a criminal offense under
T.C.A. 39-13-306, Tennessee custodial interference statute. Violation of this
Order may subject a person to arrest.
8.2 Good Faith
When mutual decision-making is designated but cannot be achieved, the parties
shall make a good faith effort to resolve the issue through the dispute resolution
process, as detailed above in Section IV.
8.3 Binding Effect
If one parent fails to comply with a provision of this plan, the other parent's
obligations under this plan are not affected.
8.4 Other Provisions
X] There are no other provisions.
There are the following other provisions:__________________________
IX. DECLARATION FOR AGREED PARENTING PLAN

(] Does not apply
[X] We agree to be bour)d by the foregoing Permanent Parenting Plan and
undersnd that it 11 bco e a Court order when acted upon by the Court.
MORITZ TULAY
//
Sworn to and subscribed before me this (

\CLC
?m
NOTARY PUBLIC
L(/!32
!
Date and place'of signature'
day of
My Commission Expires:
2001.
L4
_oS
15
Hj/3
Jot
Ktp.v, ifr,ft'-
Date and place of signature
Ml HALPETERTULAY
Sworn to and subscribed before me this 13 day of _
o4
My Commission Expires: LA
Th
2001.
NOTARY PUBLIC
ORDER OF THE COURT

It is ORDERED, ADJUDGED AND DECREED that the Parenting Plan set forth
above is adopted and approved as an order of this court.
Dated:
Judge:
____
M . 77, ~9
JUN 7 2002
Presented by Counsel:
---
S ,gnature
HOWARD G. hOGAN
1051
JamesR.LaFevor
Name
Address 800 S.Gay Street Ste. 1900
Knoxville, TN 37929-1900
Phone (865)637-6258
Name
Address
Address of Mother
Address of Father
BPR #
BPR # Signature
Phone
_MICHAEL PETER TULAY.
PAMELA MORITZ TULAY.
_9423 YUMA DRIVE__________
_8705 PERCY WAY
_KNOXVILLE, TN 37931
_KNOXVILLE, TN 37923
Dates of Tenn. Code Ann. 36-6.408

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

parenting classes attended:
Mothers certificate of successful

completion of parenting classes
was filed with ths Clerk's office
20.
on the day of
Father's certificate of successful

completion of parenting classes
was filed with this Clerk's office on
20_:
the ________ day of
Deputy Clerk
Deputy Clerk
CERTIFICATE
I, Rm.e S. o -;n S.c .o; oLtiSt tSc,S I hc0
iIJtra
cli
[If applicable] Mediation servic es p rovided by: John KandilakisChiId & Clinical
pa:tioc 0; '11 elI ottSn;! 0.0 or; w Sore not approved
Psychology, 135 Fox Road Knoxville TN Tel (865) 694-8792 OOL,0, by p ia.yn; oa;;o is ISO U.S. 15a1, postage p;tpoiii 51115
_-tf_ 4J_I
26Q
8
CIek
--
& SeatS r shascoi,4ry\
Deputj den
16
IN TUE CHANCERY COURT FOR KNOX COUNTY, TENNESSEE
PAMELA MOR1TZ TTJLAY,
)
-.
Plaintiffi,
vs.
)
)
)

Defendant.
No. 15 59-3
Noti of Entry Required
NOTICE OF ATTORNEY'S LIEN

Comes James R. LaFevor, attorney of Nickle and LaFevor, - and hereby gives notice of a
lien upon the plaintiffs right of action in this cause pursuant to Tennessee Code Annotated
23-2-102, and requests that this matter be set for a hearing prior to disbursement of any fends
whether pursuant to settlement or judgment.
pectfiilly submitted,
James R. LaFor
NICKLE and LAFEVOR
800 S. Gay Street
Knoxville, TN 37929
(865) 637-6258
(865) 637-8476 FAX
This is to certify that a true and exact copy of the foregoing Notice of Attorney's Lien
has been placed in the U. S. Mail for delivery to:
Diane M. Messer
SOBIESKI, MESSER & ASSOCIATES
900 S. Gay Street, Ste. 1801
Knoxville, TN 37902
William A. Mynatt, Jr.
SHEPPEARD & SWANSON
P.O. Box 2149 I
Pamela M. Tulay
9423 Yuma Drive
Knoxville, TN 37931
this
/7
, 2002.
day of
/
JAMES R LAFEVOR
17
C! C( COURT TRIAL NOTIC
FILE COPY
08/07/02

KNOXVILLE, TN 37902
TULAY PAMELA MORITL
vs.
TULAY MICHAEL PETER
PLEASE BE ADVISED THE

CASE No: 01-151759
ABOVE STYLED CAUSE IS SET FOR TRIAL
AT 9:30 ON 21ST DAY OF MARCH
2003
NOTICES SENT TO
W NATT WILLIAM &. JR.
;OBIESLI, WANDA G.
MESSER, DIANE M
18
p1
FILED
2002 AUG 26 PK l: 36
PAMELA MORTTZ TIJLAY,
HOV4 G. HOGAN
Plaintiff,
vs.
No. 151759-3

Defendant.
MOTION FOR INCLUSION OF LANGUAGE REFLECTING ATTORNEY'S LIEN
James R. LaFevor, moves the Court to include an acknowledgement and protection of his
statutory attorney's lien in any Final Judgment of Divorce granted in this cause. In support of the
motion, he will show as follows:
1. James R LaFevor was attorney of record for Pamela Moretz Tulay.
2. James R. LaFevor and Pamela Moretz Tulay entered into a written agreement
concerning representation whereby she agreed to pay fees for time spent. (Attached as
Exhibit A is a copy of the retainer agreement).
3. James it LaFevor performed legal services on behalf of Ms. Tulay and submitted
billings for those. (Copies of the Billings may reflect attorney-client information and
will be submitted in camera for the court's review, if necessary.)
4. After negotiations and two lengthy mediation sessions with John Harber, Pamela
Moretz Tulay decided that she would seek other counsel.
5. James R. LaFevor has filed a Notice of Lien pursuant to the statute.
6. Pursuant to court opinions, the lien needs to be memorialized in any Final Judgment of
Divorce.
1
19
THEREFORE, James R. LaFevor moves that he be granted a lien against any assets of
Pamela Moretz Tulay pending resolution of the attorneys fee issue.
day of
, 2002.
JamIR.. LaFevor
914LE and LAFEVOR
800 S. Gay Street
Knoxville, TN 37929
(865) 637-6258
This is to certify that a true and exact copy of the foregoing Motion for Attorney's Lien
has been HAND DELIVERED to:
Diane M. Messer
Attorney for Pamela Moretz Tulay
SOBIESKI, MESSER & ASSOCIATES
Knoxville, TN 37902
Attorney for Michael Peter Tulay
SHEPPEARD & SWANSON
P. 0. Box 2149
Mailed this
day of August, 2002.
44
0Y
FAMILY LAW FEES AND (OSTS AGREEMENT
DATE:
I jl_~
________
CLIENT NAME:
Qei
j-yl
ADDRESS:
9923
11'rv
11.4 !
Dr 'v'e
Street
APL
kk\ pi11
City
HOME PHONE: 'T0

PAGER/CELLULAR: fo
33J
State
(.,03
Zip Code
L1qffj WORK PHONE:

FACSIMILE:
RE:
INTRODUCTION
This document constitutes our agreement for me representing you in your failtily law matter. Please read it
c.arefiully and call me if you have any questions. Discuss it with your regular family or business lawyer if you
like. If you find this agreement acceptable, please initial each page, sign on page 3, and return it to me with
your retainer for $2,000.00. Receipt by me will initiate my representation of you.
COUNSELING
If you are not in counseling, I recommend that you consider it. The length and expense of the case is usually
affected by the intensity of the parties' feelings. During a divorce or custody dispute many people experience
emotions that are difficult to handle without professional help. I find that the money invested in psychological
help is well spent because the client is better able to cope with the stress of the case. Counseling often results in
reduced attorneys' fees.
ADVANCE PAYMENT
A minimum $2,000.00 plus filing fees advance payment is required. if the case involves disputed custody
matters, it is often more expensive and a payment of $3,500.00 may be required, depending upon the
circumstances. I will place this retainer in the client trust account and bill you against this monthly. A 1)811 of
this $2,000.00 retainer is tion-refundable, namely, $700.00 in legal fees and a $60.0 1 ) case administration
fee which includes opening, copies, postage and local faxes. Express or certified mail, ITedex, and long
distance phone/lax are charged at cost. Example: Assume I complete 3.0 hours of work ($600.00). Your
costs would be the $700.00 minimum attorney labor charge and $60.00 case administration fee, for a total of
$760.00, trorn the $2,000.00 advance l)ayflleImt, $1,240.00 would be left in your trust acount. At the
conclusion of my representation of you, and after all charges are entered against your re airier, the remainder, if
any, in the client trust account will be refunded to you. If the balance in the client trust account is depleted
before the completion of the case, you areto replenish it, unless we have reached a sepal ate written agreement
otherwise. if you have any question about your bill, please call nrc.
CHARGES
My present hourly rate is $200.00, and $50.00 per hour for my legal assistant. These rates may increase from
time to time. I compute a minimum of one-tenth (1110) of an hour for each telephone call, no matter how short
its duralion. Additional time is recorded in tenths or all hour. Written coil ununicalions are encouraged because I
read faster than I can talk. Also, written coimurmuiricatiOil creates a record for the file.
Under Tennessee ethics rules, clients must bear expenses of litigation. Therefore, in ad hition to these fees, you
also will pay out-of-pocket costs incurred in your case. The costs include: court filing lees, long-distance
faxes/phone calls, computer research time, process servers, court reporters, witness fees, travel, experts and
investigators. I will not hire experts or investigators unless you agree that they should be hired and that you pay
directly to the expert or investigator their fees as incurred.
Page 1 of 3
ex
Ir"ITIALSJDATF
A
TOTAL BILL
I do not know how much time your case will take, because I do not know what the disputed issues will be nor
how long negotiations or trial preparation will last. Your cooperation in providing information and in working
viih ine on your case can considerably expedite the case and help reduce attorney's fees. Call me as often as you
like, but please keep in mind that telephone calls do increase your expenses (although nocj.iMge will be made for
telephone calls or in-person conferences reg a rding your bills). It may cost less if you keep me updated by mail,
however, if your information needs prompt attention, please call or fax information to ore right away.
PAYMENT OF LEGAL FEES BY OPPOSING PARTY

Sometimes the court will order the other party to pay your legal fees and costs. An order is more likely to issue
when one party has substantially more income and assets than the other party. In appropriate circumstances, I
will ask the court to order the other party to pay your fees and costs. lfyou are lIre )arty wilh more income and
assets, tIre court may order Mu to pay all or a portion of the opposing party's fees.
This contract is between you and me. You are ultimately responsible for payment of the lcs and costs awarded
to me, even if the Court awards an attorney's fee. You will receive reimbursement for payments YOU have made
in tlr_ggt the other party pays as ordered, or if you have an outstanding haance owing to me, the payments
will be credited to your balance. If the other party fails to pay as ordered and you desire to start a collection or
contempt action, such an action would be a new and separate case. If such an action were not brought as a
separate case, it would mean that I would incur further costs in collecting the fees and costs owing to rue. There
are attorneys who specialize in collection, I do not.
LATE CHARGES, LIENS AND CREDIT SERVICES

Please pay your bill on receipt of the statement. If the bill is not paid promptly, your balance shall hear a one and
two-tenths (1.2) percent monthly late charge (which equals 14.4% per year APR) if you do not pay the balance
owed within thirty (30) days. Upon notice, the interest will attach at the end of each billing cycle until tire entire
hill is paid. I am not a financial institution. I strongly recommend that my clients sek methods of financing the
cnsc that avoid payment of interest at this rate. If it is necessary for me to initiate actions to collect fees, you
agree to pay the colkction costs that I incur for attorney fees and expenses. Any checks returned for insufficient
hinds shall be charged any applicable bank lees plus a $25.00 returned check fcc.
Upon signing this agreement, pending payment in full, my fee is secured by a lien on your share of the real and
personal property division.
CLIENT DUTIES
You, as the client, agree to tell me the truth, to keep me advised of your address and telephone number, to
cooperate in the preparation and trial of the case, to appear on reasonable notice for court appearances and
depositions, to pay promptly when you receive a statement, and to comply with all reasonable requests made of
you in connection with the preparation and presentation of this matter with me, and I agree not to settle or
compromise your claims without your consent, except in extreme emergencies to Protect out interest.
PARENTING EDUCATION SEMINARS

Tennessee Code Annotated 36-6-408 requires that the parents attend a seminar as soon as possible after filing
of the complaint, for a minimum of four hours. You will bear this responsibility and cost. Fees may be waived
br indigent persons.
NO GUARANTEES OF OUTCOME
You acknowledge that I have made no guarantees regarding the outcome of your case or about issues that may
he decided by the court prior to a final ruling. Statements that I make regarding the likely outcome or the range
Of possible outcomes are only my opinionnot a guarantee of results.
Page 2 of 3
crr1+ 7 I 3 1 1,
IflTIALS/DATE
DI
22
SCOPE OF REPRESENTATION
The provisions of this agreement shall apply only to the matter referenced above and, unless otherwise
specifically provided, my representation oIyou shall he for trial court proceedings only. If appellate proceedings
arc instituted, or if you want to institute appellate jrrocccdiiigs, additional fee and ictainer ;igrectncnls inut he
made. If I continue to represent you after final judgment or after our initial undertaking is ;ompleied. all of these
provisions shall apply, and we shall each be bound by these terms, unless we have a writicti agreement to the
contrary.
Effective January 1, 2001, Tennessee has enacted a new parenting plan requirement, which also calls for
alternative methods of dispute resolution. Charges will be incurred for all representation on dispute resolution.
A Permanent Parenting Plan is required in all cases involving children.
DISCHARGE AND WITHDRAWAL

You have the right to discharge me as your attorney at any time. I have the right to withdraw as your attorney
(or seek permission from the court to withdraw as your attorney) if you nhisrqpresent or fail to disclose a material
fact to me; if you fail to follow my advice; if you fail to make payments as required by this agreement: or ifyori
demand that I do something unlawful, unethical, or against my moral belief.
1 l'you require your file to be turned over to you, I must maintain a copy. Therefore, you will need to pay the
costs of copying.
CONFIDENTIALITY
Communications with me and my assistants concerning your case are generally confidential and are protected
Front disclosure under attorney-client privilege rules. This privilege is not absolute, and I may be required to
reveal irnlormiflion II' necessary to prevent a crime or fraud. Your privilege of confidentiality can also be lost if
you discuss our communications with oilier persons. lithe court is asked to decide the is:ue of attorney's fees in
Iris case, this agreement may be disclosed to the court. If, at any time, you have questions about confidentiality,
please call ine to discuss them.
CLOSING
I look forward to representing you in this matter. We welcome and encourage your input and suggestions.
Signed this
?D
day ofit,1W1
ACCEPTED BY:
,2001.
(I lUYhJL'V't[
CLIENT
ES R. LAFEV(R, ATTORNEY
KLE & LAFEVOK
An Association and not a Partnership)
I
800 S. Gay Street
Knoxville, TN 37929
Telephone: (865) 637-6258
23
0

Plaintiff;
No. 15 17/
vs.
Defendant.
NOTICE
That James K LaFevor will appear before the Chancellor on the 3rd of September, 2002,
on a motion concerning a lien for attorney's fees.
Respectfully submitted this 26th day of August, 2002.
LaFevor (. J
and LAFEVOR
9OO First Tennessee Plaza
800 S. Gay Street
Knoxville, TN 37929
(865) 637-6258
24
This is to certify that a true and exact copy of the foregoing Notice has been HAND
DELIVERED to:
Diane M. Messer
Attorney for Pamela Moretz Tulay
SOB1ESKI, MESSER & ASSOCIATES
Knoxville, TN 37902
SHEPPEARD & SWANSON
P. 0. Box 2149
DATED this
day of August, 2002.
2
25
COURT TRIAL NOTICF

FILE COPY
10116/02
CHC(

KNOXVILLE, TN 37902
TULAY PAMELA MORITZ
VS.
TULAY MICHAEL PETER
ABOVE STYLED CAUSE IS SET FOR

CONTEMPT
AT 9:30 ON 20TH DAY OF DECEMBER
2002
NOTICES SENT TO
W NATT WILLIAM A., JR.
OBIESI, WANDA G.
--
MESSER, DIANE M
W.
CCERY COURT TRIAL NOTIC

FILE COPY
03/06/03

K\0XVILLE, TN 37902
TULAY PAMELA MORITZ
VS.
TULAY MICHAEL PETER
ABOVE STYLED CAUSE IS SET FOR CONTEMPT
2003
A1 9:30 ON 21ST DAY OF
APRIL
NOTICES SENT TO
MYNATT, WILLIA!1 A., JR.
SOBIESKI, WANDA G.
MESSER, DIANE M
27
1E
IN THE CHANCERY COURT FOR KNOx COUNTY, TENNESSEE
PAMELA MORITZ TIJLAY
PLAINTIFF
VS
NO. 1S1759-3
MICHAEL PETER TULAY
DEFENDANT
SHOW CAUSE ORDER
TO THE
AND TO:
SHERIFF OF KNOX COUNTY:

MICHAEL PETER TULY
GREETINGS:
You are hereby notified, by Fiat of Chancellor
Sharon Bell
to appear in the Chancery Court

Room of Knox .County, on
2002
December 20
at
and show cause, it any you have, why you
9:30 a.m.
should not be held in contempt of the Order of this Court.
This
18th
day of
October
, 202
4
Clerk and Maste
/2'
I CERTIFY THAT I SERVED THE WITHIN SHOW CAUSE ON THE

DAY OF
, 20Q, BY DELIVERING A COPY OF THE PETITION AND SHOW
0 e 4-n he r
CAUSE TO THE DEFENDANT
--
I
f FAILED T
DAYS AFTER ISSUANCE BECAUSE
BELOW WITHIN THIRTY (30)
CIA
DEPUTY S2EIIFF
28
STATE OF TENNESSEE
Ql
THE CHANCERY COURT FOR KNOX COUNTY

PlaintiffPetitioner,
V.
I)efcndantfRespondent.
No. 1517 59-3
To the above named Defendant(Respondent:

You are hereby summoned and required to serve upon Wanda G. Sobieski
attorney, whose address is Sobieski, Messer & Associates. Riverview Tower, 900 S. Gay
Street, Suite 1801, Knoxville, Tennessee 37902, an Answer to the Petition for Contempt
herewith served upon you within thirty (30) days after service of this Sunir1soiis and
Complaint upon you, exclusive of the day of service. If you fail to do so, judgment by
default can be taken against you for the relief demanded in the Complaint.
issued and tested this
day of
, .te'
&e-?
,44-'.b Ac
Clerk
Deputy L erk
NOTICE
To the Defendant(s):
Tennessee law provides a Four Thousand Dollars ($4000) personal property
exemption from execution or seizure to satisfy a judgment. if a judgment should be
entered against you in this action and you wish to claim property as exempt, you must file
a written list, under oath, of the items you wish to claim asxempt with the clerk ef the
courL The list may be filed at any rime and may be changed by you thereafter as
necessary; however, unless it is filed . before the judgment becomes final, it will not be
effective as to any execution of garnishment issued prior to the filing of the list
Certain itenis are automaticaity exempt by law and do not need to be listed; these include
hems of necessary wearing apparel for yourself and your family and trunks or other
receptacles necessary to contain such apparel, family portraits, the family Bible, and
school books. Should any of these items be seized, you would have the right to recover
them, if you do not understand your exemption right, or how to exercise it. you may
wish to seek the counsel of a lawyer. Tenn. Code Ann. 26-2-114.
SERVICE INFORMATION
To the Process Server: Michael Peter Tulay can be served through his attorney of
-record, William A. Mynati, Jr. at Sheppcard & Swanson, 616 W. Hill Avenue, Knoxville,
Tennessee 37902.
RETUPN
Oc 4z,_
I received this summons on the - I_day of
,
I hereby certify end return that on the
(X served this summons and a P.c-fs--fL'

in the following manncr:
led-
6-_
ec'-)_c_i
) 1
'
failee -tb seve ttns so fmor,s within thirty (30) days after its issuance because:
Process
29
CHILD SUPPORT SERVICES

507 S GAY ST, SUITE 600
KNOXVILLE, TN 37902
FLED
STATE OF TENNESSEE
DEPARTMENT OF HUMAN SERVICES
(865) 862-0366
FAX (865) 862-0403
200b APR 28 P 3: 5L
HOWARD HOGAN
C/C BLDG. 400 MAIN A N
0. HOGAW
FIRST -FLOOR1 SUITE
KNOXVILLEi TN 3?902 -CLERK &MASTER
04/21/2006
RE:
PAMELA A. MORITZ V. M1CHAL P. TLJLAY

CHANCERY Court, Docket Ny(51759-3
KNOX County, Tennessee
TCSES Case: 000836172
The enclosed Order/Notice to Withhold Income For Child Support is being provided to you pursuant to
Tennessee Code Annotated, 36-5-501(b)(4).
30

KNOXVILLE, TN 37902
ME
STATE OF TENNESSEE
(865) 862-0366
SEQUOYAH CONSULTING GROUP

1]] WASHINGTON ST
PLAINVILLE, MA 02762-155
ORDER/NOTICE TO WITHHOLD INCOME FOR CHILD SUPPORT
RE:
PAMELA A. MORITZ v. MICHAEL P. TULAY

CHANCERY Court, Docket No. 151759-3
TCSES Case: 000836172
REMITTANCE INFORMATION
With your remittance you must provide the payment Turnaround Document (Employer Obligation
Letter) provided to you by the Department of Human Services, or you must provide all of the following
information.
Date payment was deducted from
employee's/obligor's income
Docket number
Court identifier
Employee's/Obligor's name
Employee's/Obligor's Social Security number
Employee's/Obligor's return address
PLEASE CONTACT THE OFFICE LISTED ABOVE IF YOU HAVE QUESTIONS ABOUT THIS NOTICE
31
JJ ORDER/NOTICE TO WITHHOLD INCOME FOR CHiD SUPPORT

0 NOTICE OF AN ORDER TO WITHHOLD INCOME FOR CHILD SUPPORT
ORIGINAL
AMENDED
TERMINATION
Date: _04121/2006
State/Tribe/Territory TENNESSEE
City/Co./Dist./Reservation KNOX
Non-governmental entity or Individual
Case Number CHANCERY 1 151759-3
SEOUOYAH CONSULTING GROUP

Employer's/Withholder's Name
111 WASHINGTON ST
Employer's/Withholder's Address
PLAINVILLE, MA 02762-2155
RE: TIJLAY. MICHAEL P.

Employee's! Obligor's Name (Last, First, ME)
J67-"- '5 376
Employee's/ Obligor's Social Security Number
000836172
Employee's/ Obligor's Case Identifier
MORITZ, PAMELA A.
Obligee's Name (Last, First, MI)
Employer's/Withholder's Federal EEN Number (if known)
ORDER INFORMATION: This document is based on the support or witholding order from TENNESSEE
You are required by law to deduct these amounts from the employee's/obligor's income until further notice.
Per _MONTH
3.900-00
current child support
1.950,00
Per MONTH
past-due child support
0 yes 0 no
- Arrears greater than 12 weeks?
Per___________________ current cash medical support

past-due cash medical support
Per
spousal support
S ___________________ Per
past-due spousal support
S ___________________ Per
S ___________________ Per ____________________ other (specify)
per MONTH
to be forwarded to the payee below.
for a total of S5,850.00
You do not have to vary your pay cycle to be in compliance with the support order. If your pay cycle does not match the ordered
payment cycle, withhold one of the following amounts
S
1,350.00 per weekly pay period.
S2,925.00 per semimonthly pay period (twice a month).
2,700.00 per biweekly pay period (every two weeks).
S5,850.00 per monthly pay period.
REMITTANCE INFORMATION: When remitting payment, provide the pay date/date of withholding and the case identifier. If the
employee's/obligor's principal place of employment is Tennessee, begin withholding no later than the first pay period occurring 14
working days after the date of 0412112006. Send payment within 7 working days of the pay date/date of withholding. The total
withheld amount, including your fee, may not exceed 50'V0 of the employee's! obligor's aggregate disposable weekly earnings.
IF the employee's/ obligor's principal place of employment is not Tennessee, for limitations on withholding, applicable time requirements,
and any allowable employer fees, follow the laws and procedures of the employee's/obligor's principal place of employment (see
#3 and
#9 , ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS).

Send check to: RECEIPTING UNIT
Make check payable to: TENNESSEE CHILD SUPPORT
before first submission.
P.O. BOX 305200
II remitting payment by EFT/EDI, call(800) 838-6911
Bank routing number._ Bank account number:_.
NASHVII .i.v, m 17229
Use this FIPS code:
If this is a Notice of an Order to Withhold:
If this is an Order/Notice to Withhold:
Print Name
Print Name Michael 1.. Adams

Title of Issuing Official Assistant Commissioner, Child Support
Title (if appropriate)
Signature
Signature
Date
0412112006
0 Court
IS IV-D Agency
U Attorney with authority under state law to issue order/notice
Date
U Attorney U Individual
U Private Entity
NOTE: Non-IV-D Attorneys, individuals, and non-governmental entities must submit a Notice of an Order to Withhold and
include a copy of the income withholding order unless, under a state's law, an attorney in that state may issue an income
withholding order. In that case, the attorney may submit an Order/Notice to Withhold and include a copy of the state law
authorizing the attorney to issue an income withholding order/notice.
IMPORTANT: The person completing this Form is advised that the information on this form may be shared with the obligor.
32
pJRL Hi
AGi

KNOXVILLE, TN 37902
STATE OF TENNESSEE
L LZ U
200b MAY - 2 P 1:53

(865) 862-0366
Fax (865) 862-0403
MICHAEL P. TULAYC
9042 LEGENDS LAKE b
KNOXVILLE, TN 37922-5258
ME,
'
ADMINISTRATIVE ORDER TO REDIRECT CHILD SUPPORT PAYMENTS
RE: PAMELA A. MORLTZ v. MICllAL P. TULAY

CHANCERY Court, Docket No/51759-3
TCSES NO: 836172
Pursuant to T.C.A. 3 6-5-803, you are hereby ORDERED to pay all future, support payments to
Central Child Support Receipting Unit, P. 0. Box 305200, Nashville, TN 37229. The payments
should include the following amounts:
$3,900.00
$.00
$.00
$ .00
$.00
$.00
$3,900.00
per
per
per
per
per
per
per
MONTH for current child support;

MONTH for child support arrears;
MONTH for current medical support;
MONTH for medical support arrears;
MONTH for current spousal support;
MONTH for spousal support arrears;
MONTH TOTAL AMOUNT
33
You must return with your payment the payment coupon provided by the Department of
Human Services. If you have not received one, contact Customer Service at 1-800-8386911. If you do not return the payment coupon, you must provide the following
information:
Docket ID: 151759-3
Court Identifier: 4709305
Your name
Your Social Security Number
Your return address
Pursuant to T.C.A. 36-5-120, failure to include the information requested above may
result in a civil penalty being issued against you.
You are hereby notified that no credit shall be given for any payments made by you or by another
person on your behalf directly to the custodial parent. Such payments would be considered to be
a gift by you or payments of an obligation other than those listed above.
It is FURTHER ORDERED that the parties complete the required information found in Exhibit
A to this order. You must provide the information immediately to the local child support office
listed above. Additionally, you are required to notify the Child Support Office listed on Exhibit
A of any changes in the information on Exhibit A within ten (10) days of the change.
You may appeal this Administrative Order by filing a written request for an administrative
hearing with the child support office shown above within fifteen (15) calendar days of the entry
date of this order. The only grounds for appealing this order are: a mistake of identity, a mistake
of fact, or that this case is not a Title IV-D case.
Failure to obey this Administrative Order may result in the imposition of civil penalties, and/or
imprisonment for contempt, or suspension of your driver's or other licenses.
If you have any questions concerning this Administrative Order, you should contact the child
support office at the above address.
Enter this
day of
A24/
/2Z2
Title IVjYdininistrator / Supervisory Designee
Administrative Order to Redirect Child Support Payments - Page 2
34
I hereby certify that a copy of this ORDER was served on MICHAEL P. TULAY PAMELA A.
,
MORITZ, and the Clerk of CHANCERY Court of KNOX County by mailing to him/her by
First Class U.S. Mail postage prepaid on 28 April, 2006.
e,e--
X~ -'~'
"
Tit1u1V-D Administrator I Supervisory Designee
Administrative Order to Redirect Child Support Payments
Page 3
35
FAILURE TO APPROPRIATELY UPDATE THIS INFORMATION OR GIVING FALSE INFORMATION

COULD LEAD TO BEING CITED FOR CONTEMPT OF COURT OR HAVING A DEFAULT JUDGMENT
ENTERED AGAINST YOU.
BOTH PARTIES MUST UPDATE THE FOLLOWING INFORMATION WITH ANY CHANGES WITHIN
10 DAYS OF THE CHANGE TO THE CLERK OF THE CHANCERY COURT, C/C BLDG. 400 MAIN
AVENUE FIRST FLOOR, SUITE 125, KNOXVILLE, TN 37902 AND THE CHILD SUPPORT SERVICES,
507 S GAY ST, SUITE 600, KNOXVILLE, TN 37902:
Father's Information
SSN: _____ - ____ -
Full Name:
Last
Residential Address:
First
Middle
Phone: ( )
Birthdate: -
Mailing Address:
Birthplace -
(if different from above)
City: ____
State:
Drivers License
LIp1o\ersNarne
Phoe
Employee s AJ&ess.
Oros
____
ilk on
IfleLlIk.
Available through Employer?

Health Insurance
( ) Yes
( ) No
Company:
Health Insurance
Address:
Cost to Employee (if any):
$
Mother's Information
Fall Name:
1iddIe
1 at
Phone:
Reidential Ades:
Birthdate:
Mail
Birthplace -
Addr:
(it J tIeren 1rn aho\e)

ate
I)ri er T icene
T7:
Phone:
Employer's Name:
Gross Income:
Employer's Address:
Total Gross Income:
Avail iNc ihroug

( )
Health Iurance
Company:
YS
1) p10
( )
No
Health baiance
Address:
Cost to En plor cc (it any:
Demographic Information - Page 2
37
Child(ren)'s Information
(1) Child's Full Name:
SSN:
Last
First
Middle
Birthdate:
(2) Child's 1u1lName:

Last
First
Middle
/ -
irthdats:
Residential ddre:
SSN:

First
Last
Middle
Birthdate:
(4) Child's full amc:
First
Last
Middle
Brthdaie:
Residental ddrss
Last
SSN:
First
Middle
Birthdate: - /
Demographic Information - Page 3
38
NON-RESIDENT NOTICE
TO:
PAMELA
-VS-
PAMELA MORITZ TIThAY
No:
MICHAEL PETER TTAY
151759-3\/
IN THE CHANCERY COURT OF KNOX COUNTY, TENNESSEE
In this cause, it appearing from the Complaint filed, which is sworn to, that the defendant
PAMELA MORITZ TITLAY
non resident
of the State of Tennessee, or
whose where-abouts cannot be ascertained upon diligent search and inquiry, so that the ordinary process of law
cannot be served upon HER
it is ordered that said defendant
Master of the Chancery Court at Knoxville, Tennessee and with

Plaintiff s Attorney whose address is
you
. This notice will be published in the
consecutive weeks.
This
17th
day of
KIMBERLY R. TAYLOR
9 7 2 -Ir Kingston Pike. Suite 703,
within thirty
or a judgment by default will be taken against

you
ifie an answer with the Clerk and
May
(3
0) days of the last date of publication
and the cause set for hearing Ex Parte as to

READING EAGLE
for four (4)
P. 0. Box 582, Reading, Pennsylvania 19603Tel: (610) 371-5100
058237111
,2007
CT
{ No. 1405442
2007
Proof of Publication of Notice in Reading Eagle

Under Act No.
Commonwealth of Pennsylvania,
County of Berks
587,
Approved
May 16,1929.
LU1HSCP
} ss:
H 9:Q7
18
u G. HOGN'1
Jo Mm Gottschall, Assistant Secretary, READING EAGLE COMPANY, of the County and Commonwealth aforesaid, being duly sworn,
deposes and says that the READING EAGLE established January 28, 1868 is a newspaper of general circulation published at 345 Penn
Stjeet, City of Reading, County and State aforesaid, and that the printed notice or publication attached hereto is exactly the same as printed
and published in the regular edition and issues of the said READING EAGLE on the following dates, viz.:
Sunday, May 20, 2007, A.D.

Sunday, May 27, 2007, A.D.
Sunday, June 3,2007, A.D.
Sunday, June 10, 2007, A.D.
Reading Eagle
Reading Eagle
Reading Eagle
Reading Eagle
Effective July 1, 2002 Reading Times Ceased Publication. The Reading Eagle will be a daily morning and Sunday edition.
Affiant further deposes that this person is duly authorized by READING EAGLE COMPANY, a corporation, publisher of said
READING EAGLE, a newspaper of general circulation, to verify the foregoing statement under oath, and affiant is not interested in the
subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place, character of
publication are true.
Copy of Notice or Publication
(y1
Jo Ann Ciottschall
Sworn to and subscribed before me this 10 th day
No14.RESIDENr.NaTtc
MORITZ
7ULAY)
'MoRrrZ -
ULAY) - VI
ETEP TULAY
511CC-I
IN THE
- -
--
of June ' 2007
-0-7- _M------------
46ERY COURT
C COUNTY.
lESSEE -
------Notary
-
Statement of Advertising Costs
MORITZ VS TULAY
COMMONWEALTH OF PENNSYL\'A
KIMBERLY R TAYLOR ESQ

9724 KINGSTON PIKE
SUITE 703
KNOXVILLE, TN 37922
NOIARIAL SEAL
ANN L. LIPTAK NOTARY PUBLIC

CITY OF READING, BERKS COUNTY
MY COMMISSION EXPIRES OCT 2, 2008
To READING EAGLE, DR:

For publishing the notice or publication
attached hereto on the above slated dates
cane set lc( 40a,rM exjlarre
as ID yod - Ths ouBce wdl be
published n - the READING

EAGLE P.O. Box in. Reaa'ng,
PernuyJvania 19603.058Z I Tel:
(610) 371-1OC f four (4)
cgnsecutive weeIc.
ThhiilIt' day a' May, 2L07,

14p,.,4 e. IIsn
CLERK AND MASTER
Probating same
Total
$624.00
$5.00
$629.00
Publisher's Receipt for Advertising Costs
The READING EAGLE COMPANY, publisher of the READING EAGLE, a newspaper

of general circulation, hereby acknowledges receipt of the aforesaid notice and
publication costs and certifies the same have been duly paid.
READING EAGLE COMPANY, a Corporation
40
uJ

501-S GAY ST, SUITE 400
KNOXVILLE, TN 37902
STATE OF TENNESSEE
DEPARTMENT OF HUMAN SER IUS'
25
(865) 862-0366
FAX (865) 862-0403
HOWARD HOGAN
C/C BLDG. 400 MAIN AVENUE
FIRST FLOOR, SUITE 125
KNOXVILLE, TN 37902
09/19/2007
RE:
PAMELA A. MORITZ v. MICHAEL P. T14,AY

CHANCERY Court, Docket No. 151759-3 'I
TCSES Case:
000836172
The enclosed Order/Notice to Withhold Income For Child Support is being provided to you pursuant to
Tennessee Code Annotated, 36.5-501(b)(4).
41
A.
AGRWU

KNOXVILLE, TN 37902
)RE
17 V
STATE OF TENNESSEE
(865) 862-0366
SEQUQYAH CONSULTING GROUP

153 PLEASANT ST STE 4
ATTLEBORO, MA 02703-2444
MODIFIED ORDER/NOTICE TO WITHHOLD INCOME FOR CHILD SUPPORT
RE:
PAMELA A. MORITZ v. MICHAEL P. TULAY

CHANCERY Court, Docket No. 151759-3
TCSES Case:
000836172
IMPORTANT NOTICE ***

A. The Attached Order Modifies An Existing Income Assignment Order
The amount shown on the first page of this order is the new total that you should deduct. This new
amount should be substituted for, and not added to the amount you were previously ordered to
deduct for this particular tribunal/ease number. This modification does not affect any other deductions
you may have been ordered to make for any other case(s) involving this same obligor/employee.
E If this box is checked, you are no longer required to withhold income for this employeefobligor
for the case specified at the top of the first page of the order. This order to stop deducting from this
employee's/obligor's income only affects the case specified in the attached order. It does not affect any
other deductions you may have been ordered to make for any other cases involving this same
employee/obligor.
B. Remittance Information
With your remittance you must provide the payment Turnaround Document (Employer Obligation
Letter) provided to you by the Department of Human Services, or you must provide all of the
following information.

Docket number
Court identifier
Employee's/Obllgor's return address
42
PLEASE CONTACT THE OFFICE LISTED ABOVE IF YOU HAVE QUESTIONS ABOUT THIS NOTICE
ORDER/NOTICE TO WITHHOLD INCOME FOR CHILD SUPPORT
0
0
NOTICE OF AN ORDER TO WITHHOLD INCOME FOR CHILD SUPPORT

ORIGINAL
(]
AMENDED
[J
TERMINATION
Date: _09/19/2007
State/Tribe/Territory TENNESSEE
City(Co.jDist.jkeservation
KNOX
Non-governmental entity or Individual
Case Number CHANCERY I 151759-3
SEOUOYAH CONSULTING GROUP
Employer's! Withholder's Address
ATTLEBORO, MA 02703-2444
Employer's/Withholder's Federal EJN Number (if known)
RE: TIJLAY, MICHAEL P.

Employee's/Obligor's Name (Last, First, MI)
167-44- 5 376
Employee's/Obligor's Social Security Number
000636172
Employee's/ Obligor's Case Identifier
MORITZ, PAMELA A.
ORDER INFORMATION: This document is based on the support or witholding order from TENNESSEE
You are required by law to deduct these amounts from the employee's/obligor's income until further notice.
1.025.00
Per MONTH
$
past-due child support
- Arrears greater than 12 weeks?
S _____________________ Per
S _____________________ Per ______________________ current cash medical support

S ____________________ Per
spousal support
S ____________________ Per
S ____________________ Per
Per _____________________ other (specify)
S ______________
to be forwarded to the payee below.
1,025.00
per MONTH
for a total of $
0 yes 0 no
payment cycle, withhold one of the following amounts:
S236.53 per weekly pay period.
$473.07 per biweekly pay period (every two weeks).
S
S
51250 per semimonthly pay period (twice a month).

1,025.00 per monthly pay period.
REMITTANCE INFORMATION: When remitting payment, provide the pay date/date of withholding and the case identifier. If the
employee's/obligor's principal place of employment is Tennessee, begin withholding no later than the first pay period occurring 14
working days after -the date of 09119/2007. Send payment within 7 working days of the pay date/date of withholding. The total
withheld amount, including your fee, may not exceed 50% of the employee's/obligor's aggregate disposable weekly earnings.
If the employee's/obligor's principal place of employment is not Tennessee, for limitations on withholding, applicable time requirements,
and any allowable employer lees, follow the laws and procedures of the employee's/ohligor's principal place of employment (see #3 and
#9 , ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS).
Send check to: RECEIPTINGUNIT
Make check payable to: TENNESSEE _CHILD SUPPORT
P.O._ BOX 305200
IF remitting payment by EFT/EDI, call (800)838-6911
NAHVTI J& TN 17 7 29
Use this FIPS code: - Bank routing number:_ Bank account aumber:_.
II this is an Order/Notice to Withhold:

Print Name M,ehapl I A dame
Title of Issuing Official Assistant Commissioner, Child Support
If this isa Notice of an Order toWithholdPrint Name

Signature
Date
Signature
Date
IV-D Agency
0911912007
D Court
0 Attorney 0 Individual
0 Private Entity
0 Attorney with authority under state law to issue order/notice

NOTE Non-IV-D Attorneys, individuals, and non-governmental entities must submit a Notice of an Order to Withhold and
include a copy of the income withholding order unless, under a state's law, an attorney in that state may issue an income
withholding order. In that case, the attorney may submit an Order/Notice to Withhold and include a copy of the state law
authorizing the attorney to issue an income withholding order/notice.
IMPORTANT: The person completing this Form is advised that the information on this form may be shared with the obligor.
43
--
Page 1 of 1
11/14/2007 09:06:30
Summary of NOTICES Printed

TTJLAY PAMELA MORITZ VS. TULAY MICHAEL PETER
Case No: M-01-151759 Please be advised the above
styled case is set for HEARING (HEA) at 09:30 AM on
Friday, 11/30/2007.
MOYERS, MICHAEL W
Name
TAYLOR, KIMBERLY R
TULAY, MICHAEL PETER
Address
Trial Notice Date
9724 KINGSTON PIKE / SUITE 703 KNOXVILLE, TN 37922 11/30/2007

9042 LEGENDS LAKE LANE KNOXVILLE, TN 37922
11/3012007
44
Page 1 of 1
12/04/2007 11:30:12

TULAY PAMELA MORITZ VS. TULAY MICHAEL PETER
styled case is set for HEARING (flEA) at 09:30 AM on
Friday. 12/21/2007.
MOYERS, MICHAEL W
Name
Address
Trial Notice Date
TULAY, PAMELA MORITZ
2164 HIGHLAND AVEMT PENN, PA 19606
12/21/2007
TAYLOR, KIMBERLY R
45
FROM :Southeast Branch Library
FAX NO. :961G55G669
4.20 227 5:53FM P2
2164 Highland Avenue

Reading, PA 19606
December 20, 2007
Howard G. Hogan
Clerk and Master
Chancery Court
400 Main Street
Suite 125
Knoxville, TN 37902
RE: Docket No. 151759-3
Dear Mr. Hogan,
A re-hearing in this case has been set for Friday, December 21,
2007 at 9:30 A.M.
However, due to a four-day (Sunday 12/16 through Wednesday
12/19) loss of power due to a severe ice storm in Pennsylvania, and
having to seek shelter elsewhere with my children, I am unable to attend
this re-hearing.
I appreciate the court's understanding in this matter. I hope that
the re-hearing can be rescheduled for a future date.
Respectfully,
Pamela Moritz
This letter faxed to (865)215-2920

on Thursday, December 20, 2007
rS*n
FROM
FAX NO. :96106556669
:Southeast Branch Library
,-,~ )
05:52PM Pt
2(
To: ft o
0/0
4:.20 2007
V
no
cuw-
C k -,~; im- 1C7
in
~ 0"
V'VL r
F(Zow-
0 ace4-J7
C
El)
'
~~ Ull N
Ii o
47
I!
\fl
ENNESSEEDJE ii
PAMELA MORJTZ (formerly TULAY),
Original Plaintiff7Respondent,
. nUN
V.
Docket No. 151759-3'
Notice of Entry Requested
Original Defendant/Respondent.
MEDIATION ORDER
Pursuant to the Alternative Dispute Resolution Requirements of the Permanent Parenting

Plan, the parties shall engage in mediation with
not later than
Apri z g,
co 9
'i
v; said mediation to ccur
to attempt to resolve all matters currently pending
before this Court.

ENTER this 7 k day of
, 2007.
APPROVED FOR ENTRY:
skI :IJZ.iIh:!!
J!)S.SUjI.
I"H 1010,
CERT1FCATE
. icgn bc.y cctiiy t:;at I
How
tii3 a trae d
pE
NI
&{ZM&Z
(3
48
D
Cr
Pagel of 1
01/07/2008 13:58:42

styled case is set for TRIAL (TRI) at 09:30 AM on
Wednesday. 5/14/2008.
MOYERS, MICHAEL W
Name
TAYLOR, KIMBERLY R
Address
Trial Notice Date
9724 KINGSTON PIKE I SUITE 703 KNOXVILLE, TN 37922 05/14/2008

2164 KIGHLANDAVEMT PENN, PA 19606
05/14/2008
49
F!
it
State of Tennessee
Department of State
Division of Business Services
312 Eighth Avenue North
6th floor Wm. ft Snodgrass Tower
Nashville, Tennessee 37243
Case Number: 1.5 1759-3 v/
70070220000300898172
1/16/2008
Date
Certifed Number
HON. HOWARD G. HOGAN

KNOX COUNTY-CHANCERY COURT
ROOM 125, C/c BLDG, 400 MAIN ST
RE:
PAMELA MORITZ TULAY
VS: MICHAEL PETER 1W LAY
Dear Clerk:
Enclosed are the following papers in the above styled case:
Original Summons
Affidavit and Endorsement
!I
Registered or Certified Return Receipt signed by:

PAMELA MORITZ
Registered or Certified letter returned undelivered with notation:
li~
Sincerely:
a"~
'
Riley C. Darnell
enclosures
Initials:
Q.E
CC: TAYLOR
S5-4210 (Rev. 12/96)
WA No. 1003
50
Im
IE
AFFIDAVIT
and
ENDORSEMENT
1/1612008
Date
70070220000300898172
Certified Number
Case Number: 151759-3

RE:
PAMELA MORITZ TULAY
VS:
MICHAEL PETER TULAY
I
having been duly authorized by Riley C. Darnell, Secretary of State
BOB GRUNOW
of Tennessee, do hereby make oath on his behalf and under authorization as follows:
Thursday. December 27. 2007
That on
, I received from the plaintiff the original
and certified copies of the Summons and Complaints issued against the defendant:
1
PAMELA MORITZ TLJLAY

whose address is:
2164 HIGLAND AVENUE. READING, PA 19606
Wednesday. January 02. 2008
and that on
, I mailed by registered or certified returnreceipt mail the certified copies of the Summons and Complaint to the defendant at the above address together with written notice that service was so made. I further make oath that the return
receipt for the registered or certified letter was received at my office in Nashville, Tennessee, on
Wednesday. 3anuarv 16. 2008
of KNOXVILLE
, and returned to
, Tennessee on Wednesday. January 16, 2008
Riley C. Darnell
Subscribed and sworn to before me,
this 16TH
day of JANUARY
f1
b
, 2008
PC/?
NOTARY PUBLIC
My commission expires 1-4-2010
( f
I
I
C)
ST1TE\
OF
\
' IT
NOTARY
DUC
51
ff!~

PAMELA MORITZ TIJLAY,
Original Plaintiff/Respondent,
Docket No. 151759-3
I',

Original Defendant/Petitioner.
TO: PAMELA MOPJTZ TIJLAY

Reading, Pennsylvania 19606
You are hereby summoned and required to serve upon Kimberly R. Taylor
Plaintiff's attorney, whose address is:
9724 Kingston Pike, Suite 703
(865) 693-3080
a true copy of the answer to the Petition for Modification of Child Support and Petition for
Modification of Permanent Parenting Plan which is herewith served upon you, within 30 days
after service of this summons upon you, exclusive of the day of service. You will file the original
with the Court.
If you fail to do so, judgment by default will be taken against you for the relief demanded in the
complaint.
2007 at
Issued this /day of
day of
-.
M.
Witness Clerk and Master of said Court, at office in Knox County, Tennessee, the
2007.
/
'
4/
Clerk and Master

BY:
Deputy Cle4 and Master
(This summons is issued pursuant to Rule 4 of the Tennessee Rules of Civil Procedure.)
Lfl1
93
NOTICE
TO THE DEFENDANT(S):
Tennessee law provides a four thousand dollar ($4,000.00) personal property exemption from execution or seizure to
satisfy a judgment. If a judgment should be entered against you in this action and you wish to claim property as
exempt, you must file a written list, under oath, of the items you wish to claim as exempt with the clerk of the court.
The list may be filed at any time and may be changed by you thereafter as necessary; however, unless it is filed
before the judgment becomes final, it will not be effective as to any execution of garnishment issued prior to
the filing of the list. Certain items are automatically exempt by law and do not need to be listed; these include items
of necessary wearing apparel (clothing) for yourself and your family and trunks or other receptacles necessary to
contain such apparel, family portraits, the family Bible, and school books. Should any of these items be seized, you
would have the right to recover them. If you do not understand your exemption right or how to exercise it you may
wish to seek the counsel of a lawyer.
Received this
day of
2007,
Deputy Sheriff.
RETURN OF SERVICE OF SUMMONS

2007, I served this summons and
I hereby certify and return that on the _____ day of
Petition for Modification of Child Support and Petition for Modification of Permanent Parenting Plan, the proposed
Permanent Parenting Plan, Fiat and Injunction upon the Respondent by
failed to serve this summons within 30 days after its issuance because______________________________________
Sheriff-Deputy Sheriff/Private Process Server
STATE OF TENNESSEE, KNOX COUNTY

CHANCERY COURT AT KNOXVILLE
INJUNCTION
MICHAEL PETER TULAY VS
PETITIONER
No. 15759-3
PAMELA MORITZ (formerly Tulay)

DEFENDANT
To the Sheriff of Knox County - Greeting:

And to PAMELA MORITZ And to all Counselors, Attorneys, solicitors and Agents, and to
each and every one of them
Greeting:
"Whereas Michael Peter Tulay has lately flied a Petition for Modification bill of Complaint in said
Chancery Court at Knoxville, against you, the said defendant to be relieved touching the matter set forth in
said bill in which it is charged that Pamela Moritz your actings and doings in the premises are contrary to
equity and good conscience, and whereas, the Honorable Michael Moyers, Chancellor of the Chancery
Court at Knoxville, Tenn., in said State has ordered that an injunction issue, as prayed by complaint.
Therefore, in consideration of said flat, and of the particular matters in said Bill set forth, you, the
said defendant and the persons before named, and each and every one of you, are hereby strictly
commanded and enjoined, under the penalty of a contempt of Court, from interfering with the Petitioner's
co-parenting time and rights set forth in the Permanent Parenting Plan proposed by the Father which has on
this date been approved as a temporary Order, until the further order of the said Chancery Court in the
premises.
Witness my hand at office, this 21ST day of December, A.D. 2007.
CL AND MASTER
D. C.
I CERTIFY THAT I SERVED THE WITHIN INJUNCTION ON THE
DAY OF
_, 20,
BY DELIVERING A COPY OF THE PETITION AND INJUNCTION TO THE DEFENDANT
ERSONALLY,OR BY__________________
I FAILED TO SERVE THE DEFENDANT(S) LISTED DELOW WITHIN THIRTY (30) DAYS
AFTERAFTER ISSUANCE BECAUSE
DEPUTY SHERIFF
54
A Signature
Complete items 1, 2, tha 3. Also complete

Item 411 Restricted Delivery Is desired.
or on the front If space permits.
DAgent
0 Addressee
X
B. A ved by (Th*ted/me)
-
C Date, DeIiv'
'L
/ C. Is delivery address different from Item 1? 0 Yes
0 No
If YES, enter delivery address below
PAMELA MORITZ TULAY

2164 HIGLAND AVENUE
READING, PA 19606
Uill fihullI
172 *
0 0 8 9 8
2.ArtlaieNumber
PS Form
3811,
0 Certified Mail 0 Express Mall

O Return RecelptforMerthandlse
0 Registered
0 lnsumd.Mall 0
4. Restricted Delivery? (Extra FeO
Yes
70070220 0003 0089 8172

February OO4
102595-C2-M-i54O
55
in
Page 1 of 1
02/05/2008 18:39:39

TULAY PAMELA MORJTZ VS. TULAY MICHAEL PETER
styled case is set for HEARING (flEA) at 09:30 AM on
Tuesday, 4/1/2008.
MOYERS, MICHAEL W
Name
TAYLOR, KIMBERLY R
Address
Trial Notice Date

2164 IUGHLAI'.DAVEMT PENN, PA 19606
04/01/2008
03/30/2008 22:01 FAX 865 983
ROSE & MOFFATr, PLLC
PAMELA MORITZ (FULAY),
1002
Original P)alntiffIRespondent,
VS.
- ...
. 'IOGAN
Original Defexdant/Petitioner.
NOTICE OF APPEARANCE
Comes now Jason C. Rose of Rose & Moffatt, PLLC, and files this Notice of Appearance
in the above-styled cause, noting his appearance as counsel of record for the Respondent,, Pamela
Moritz 1'u1ay), herein
This the 3,
- day of March, 2008.

'V
11
J,AN C. ROSE, (BPR# 017543)

1t65e & Moatt, PLLC
200 F. Broadway Avenue, Suite 515
Maryville, Tennessee 37804
Phone: (865) 983-2222
Fax: (865) 983-1211
The undersigned hereby certifies that a true and exact copy of the foregoing pleading has
been sent to all interested parties or their attorneys by hand delivery or by placing the same in the
United States Mail, postage pre-paid, on this :3 day of Manth,, 2008.
57
RM
PI
Page 1 of 1
03/31/2008 13:33:26

styled case is set for HEARING (HEA) at 09:00 AM on
Tuesday. 4/22/2008.
MOYERS, MICHAEL W
Name
Address
ROSE, JASON C.
200 E BROADWAY AVE SUITE 515 MARYVILLE, TN 37804 0412212008
TAYLOR, KIMBERLY R
Trial Notice Date
58

PAMELA MORITZ (TULAY),
P1:12:15
'OYu G. HQGAJ
Original PlaintiffYRespondent,
VS.
)
)
Case No.: 151759-3"
)
)
NOTICE OF APPEARANCE
Comes now Jason C. Rose of Rose & Moffatt, PLLC, and files this Notice of Appearance
in the above-styled cause, noting his appearance as counsel of record for the Respondent, Pamela
Moritz (Tulay), herein.
This the 31
day of March, 2008.
4N C. IOSE, (BPR # 017543)

k'se &Moftt, PLLC
200 E. Broadway Avenue, Suite 515
Phone: (865) 983-2222
Fax: (865) 983-1211
The undersigned hereby certifies that a true and exact copy of the foregoing pleading has
been sent to all interested parties or their attorneys by hand delivery or by placing the same in the
day of March, 2008.
United States Mail, postage pre-paid, on this 3 \.
59
I!
PAM1'T A 1%4flPTT7 (TTTT AV)
Vii
r'
Original Plaintiff'Respondent,
VS.
)
Case No.: 151759-31
)
)
)
)
MOTION FOR WITHDRAWAL OF COUNSEL
Comes now Attorney Jason C. Rose, individually, and on behalf of the law firm of Rose &
Moffatt, PLLC, and moves the Court to be allowed to withdraw as the attorney of record for the
Respondent, Pamela Moritz, and in support thereof would show as follows:
1.
That the client, Pamela Moritz, has stated in writing that she wishes to terminate the.
representation by Jason C. Rose, individually, and the law firm of Rose & Moffatt, PLLC, effective
immediately.
2.
Movant would show that withdrawal will not cause foreseeable prejudice to the rights
of client.
3.
Counsel for the Petitioner has been contacted regarding this motion.
day of
/l/!cA.\/
3 2008.
SON C. ROSE, (BPR # 017543)

se & Moffatt, PLLC
200 E. Broadway Avenue, Suite 515
(865) 983-2222
Page 1 of 2
MR
I!
15
The undersigned hereby certifies that a true and exact copy of the foregoing Motion for
Withdrawal of Counsel has been sent to all interested parties or their attorneys by either placing same
in the United States Mail, postage prepaid, or by hand delivery.
,200
This the(f1dday of
ATTORNEY
Page 2 of 2
61

PAMELA MORITZ TULAY (now MORITZ),
Plaintiff ("Mother"),
12
VS.
No. I 1759

Defendant ("Father").
TCSS NoO8361 72
RE: PETER MICHAEL TULAY

MONICA CLAIRE TULAY
MARK KOLBE TULAY
("Children")
42
DOB 7-29-88
DOB 10-24-89
DOB 5-7-99
ANSWER
In this cause, the Mother comes, by and through her undersigned counsel, and responds
to the Petition for Modification of Child Support as follows:
1.
Any allegations pertaining to statistical information concerning the parties and
children of the parties (if applicable) are generally admitted, with the right to specifically amend
this Answer being reserved upon obtaining further information and/or discovery.
2.
If applicable, any allegations pertaining to prior orders of this Court and/or any
other Court(s) are admitted only as written and/or indicated within the records of such Court(s).
3.
If applicable, any allegations of willfully contemptuous acts and/or omissions are
denied, with the right to specifically amend this Answer being reserved upon obtaining further
information and/or disocovery.
4.
All other allegations are denied, with the right to specifically amend this Answer
being reserved upon obtaining further information and/or discovery.
5.
It is denied that the requesting party is entitled to any relief whatsoever.
WHEREFORE, it is respectfully submitted that the requests for relief to which this
Answer applies be denied so as to dismiss the cause of action relative to such requests, with all
Court costs being taxed accordingly and with the client of W. Brian Starnes being awarded a
judgment for the reimbursement of attorney's fees and litigation expenses.
Respectfu
W. BRIAN SThRNES (BPR 011323)

ATTORNEY FOR MOTHER
6408 Papermill Drive, Suite 231
Telephone: (865) 588-0030
(865) 588-0322
Telefax:
IFN
I certify that counsel for the Father has been duly

served with a true and exact copy of this Answer by
placing same in the US Mail with sufficient postage and
marked for delivery to her last known address
(9724 Kingston Pk. #703, Knoxville, TN 37922),
this 19th day of May, 2008.
62

VS.
Nbk. 161 7W4

TCSESFO008361 72

MONICA CLAIRE TULAY
MARK KOLBE TULAY
("Children")
DOB 7-29-88
DOB 10-24-89
DOB 5-7-99
ANSWER
In this cause, the Mother comes, by and through her undersigned counsel, and responds
to the Petition for Modification of Child Support and Petition for Modification of Permanent
Parenting Plan as follows:
1.
Any allegations pertaining to statistical information concerning the parties and
children of the parties (if applicable) are generally admitted, with the right to specifically amend
this Answer being reserved upon obtaining further information and/or discovery.
2.
If applicable, any allegations pertaining to prior orders of this Court and/or any
other Court(s) are admitted only as written and/or indicated within the records of such Court(s).
3.
If applicable, any allegations of willfully contemptuous acts and/or omissions are
denied, with the right to specifically amend this Answer being reserved upon obtaining further
information and/or disocovery.
4.
All other allegations are denied, with the right to specifically amend this Answer
being reserved upon obtaining further information and/or discovery.
It is denied that the requesting party is entitled to any relief whatsoever.
5. .
WHEREFORE, it is respectfully submitted that the requests for relief to which this
Answer applies be denied so as to dismiss the cause of action relative to such requests, with all
Court costs being taxed accordingly and with the client of W. Brian Starnes being awarded a
judgment for the reimbursement of attorney's fees and litigation expenses.
Respectfully submitted,
W. BRIANSMI'1ES (BPR 011323)

ATTORNEY FOR MOTHER
Telephone: (865) 588-0030
Telefax:
(865) 588-0322
CERTIFICATE.
ATTORNEY AT LAW

served with a true and exact copy of this Answer by
63
KM
Page 1 of 1
05/23/2008 11:04:50

TULkY PAMELA MORITZ VS. TULAY MICHAEL PETER
styled case is set for ALL PENDING MOTIONS (APM)
at 09:30 AM on Tuesday, 6/24/2008.
Q.
(\J_
MOYERS, MICHAEL W
Name
Address
Trial Notice Date
STARNES, W. BRIAN
6408 PAPERMILL SUITE 231 KNOXVILLE, TN 37919
06/24/2008
TAYLOR, KIMBERLY R
64
Ic,

No. 151759-3'/
TCSES No. 000836172

MONICA CLAIRE TULAY
MARK KOLBE TULAY
("Children")
DOB 7-29-88
DOB 10-24-89
DOB 5-7-99
NOTICE OF TRIAL CALENDAR CONFLICT

In this cause, counsel for the Mother comes and notifies all concerned of his inability to
appear before this Honorable Court on June 24, 2008 due to his trial calendar conflicts that day
in other Courts (Ciroula and Hall cases).
su
W. BRIAN STARNES (BPR 011323)

ATTORNEY FOR MOTHER
Telephone: (865) 588-0030
(865) 588-0322
Telefax:
CcATF7
ATTORNEY AT LAW

served with a true and exact copy of this Notice by
65

I.
VS.
No. 151759-3',"

TCSES No. 000836172

MONICA CLAIRE TULAY
MARK KOLBE TULAY
("Children")
37
DOB 7-29-88
DOB 10-24-89
DOB 5-7-99
MOTION TO PERMIT WITHDRAWAL OF COUNSEL

In this cause, W. Brian Starnes comes and moves for the entry of an Order permitting
him to withdraw as counsel for the Mother inasmuch as a dispute has arisen between them
regarding their respective contractual obligations pertaining to Mr. Starnes' continuing
representation of her interests that cannot be resolved, thereby rendering Mr. Starnes unable to
continue as her counsel, with her having sufficient time within which to decide to either retain
successor counsel of record or proceed pro se prior to any hearings that may be scheduled.
Respectfully submitted,
W. 'BR1A1STARNES (BPR 011323)

ATTORNEY FOR MOTHER
Telephone: (865) 588-0030
Telefax:
(865) 588-0322
CERTIFICATE OF SERVICE:
I certify that the Mother & counsel for the Father have
each been duly served with a true & exact copy of
this Motion by the placement of same in the US Mail
with sufficient postage & marked for delivery to their
respective last known addresses (2164 Highland Ave.,
Reading, PA 19606; 9724 Kingston Pk. #703, Knoxville, TN
37922), this 16th day of June, 2008.
66
I!
PAMELA MORITZ TULAY (now MORITZ

17
VS.
37
NlS7Sg3
TCSES No. 000836172


MONICA CLAIRE TULAY
MARK KOLBE TULAY
("Children")
DOB 7-29-88
DOB 10-24-89
DOB 5-7-99
NOTICE OF HEARING
TO: MS. PAMELA MORITZ

2164 HIGHLAND AVE.
READING, PA 19606
ATTY. KIMBERLY R. TAYLOR

9724 KINGSTON PK. #703
KNOXVILLE, TN 37922
Please take notice that the self-explanatory Motion to Permit Withdrawal of Counsel filed in this
cause by Attorney W. Brian Stames shall be considered by this Honorable Court on the 26th
day of June, 2008 at 9:00 a.m. and that, absent the appearance of the Mother and the
presentation of an appropriate objection to the procedural relief sought within said Motion, the
Order Permitting Withdrawal of Counsel with Award of Judgment submitted for consideration
herewith may be found to be appropriate for the reasons set forth therein and may be entered
at that time.
Al lUkNT 1UNIVIUIrItN

Telephone: (865) 588-0030
(865) 588-0322
Telefax:
I certify that the Mother & counsel for the Father have
this Notice by the placement of same in the US Mail
67
IF
VS.
No. 1517594
U)
110 ~m
1~[6
TCSES No. 000836172
JUN
MONICA CLAIRE TULAY

MARK KOLBE TULAY
("Children")
2 6 2003
DOB 7-29-88 HOWARD G. HOGAN

/ 0 79.
DOB 10-24-89
DOB 5-7-99
ORDER PERMITTING WITHDRAWAL OF COUNSEL
Upon the Motion to Permit Withdrawal of Counsel filed herein by W. Brian Starnes and
for good cause shown therein, it is found that the relief sought therein is appropriate and that
the rights and interests of the Mother will not be jeopardized upon the granting of same.
Accordingly, it is hereby ORDERED, ADJUDGED, AND DECREED that W. Brian
Starnes is permitted to withdraw as counsel for the Mother, with any subsequent pleadings,
notices, Orders, etc. being served upon the Mother at her last known address reflected
hereinbelow and with this matter remaining set for a hearing before the Honorable Michael W.
Moyers on the 45tflj day of July, 2008 at 9:30 a.m. regarding all pending Motions only.
ENTER this
2 'day of June, 2008.
APPROVED FOR ENTRY:
__________________________________________________________
BRIAA T
NES (BPR 011323)
WI THDRAW ING ATTORNEY FOR MOTHER
6408 Paperrriill Drive, Suite 231

Telephone: (865) 588-0030
Telefax:
(865) 588-0322
1. Howard a . Hogan hereby certify that I have
__Af/JJ1
V
to an
a c curate copy of the loregoing
have not approved

parties or their attorney at record who
same, by placing same in the
292 5-y
Op
u.s. htahl, postage prepa i d
this
, 2 O22
erie & vaster CjcerC
V.~Ui u. iuw tIVLW'

pto
I certify that the Mother & counsel for the
tl1g r"Whve
this Order by the placement of same in the US Mail
,
mailed a true eul
E1
Page 1 of 1
06/19/2008 10:39:29

TULAY PAMELA MOIUTZ VS. TULAY MICHAEL PETER
styled case is set for MOTION (MOT) at 09:00 AM on
Thursday. 6/26/2008.
MOYERS, MICHAEL W
Name
Address
Trial Notice Dati
2164 HIGHLAND AVE MT PENN, PA 19606
06/26/2008
STARNES, W. BRIAN
6408 PAPERMILL SUITE 231 KNOXVILLE, TN 37919
06/26/2008
TAYLOR, KTh'[BERLY R
135 S. DAVID LN. KNOXVILLE, TN 37922
06/26/2008
69
23Page 1 of 1
06/26/2008 09:19:47

TULAY PAMELA MORITZ VS. TtJLAY MICHAEL PETER
styled case is set for ALL PENDING MOTIONS (APM)
at 09:30 AM on Wednesday, 7/23/2008.
MOYERS, MICHAEL W
Name
Address
Trial Notice Dat
TAYLOR, KIMBERLY R
135 S. DAVID IN. KNOXVILLE, TN 37922
07/23/2008
2164 HIGHLAND AVE M
07/23/2008
Pkt16
Fkad i fig ,Pf
70
KM
PAMELA MORITZ (then TULAY),
: 06
Original Plaintiff7Respondent,
)
V.
Docket No. 151759-3
Defendant/Petitioner.
MOTION TO COMPEL DISCOVERY AND FOR SANCTIONS AND

NOTICE TO APPEAR FOR HEARING
Comes the Petitioner, Michael Peter Tulay, through counsel, pursuant to Rule 37 of the
Tennessee Rules of Civil Procedure, and moves this Court for an Order compelling the
Respondent, Pamela Moritz, to comply with discovery and respectfully shows unto this Honorable
Court as follows:
1.
On May 21, 2008, Interrogatories and Requests for Production of Documents were
sent to Pamela Moritz.

2.
On May 22, 2003, Counsel for Michael Peter Tulay learned that Brian Starnes was
now representing Pamela Moritz, and a revised set of Interrogatories and Requests for Production
of Documents were subsequently hand delivered to Brian Stames on May 23, 2008.
3.
Said Responses were due to be tendered not later than June 23, 2008. As of July 11,
2008, no responses have been received by Counsel for Mr. Tulay.

4.
Counsel for the Petitioner would aver that Pamela Moritz has had more than
adequate time to fully and adequately respond to the Interrogatories and Requests for Production of
Documents.
5.
The Petitioner would request that this Court order that all information requested in
discovery by the Petitioner to the Respondent be immediately and fully responded to by Pamela
1
7
KM
Moritz.
6.
The Petitioner would request this Court to levy sanctions against the Respondent for
her failure to comply with discovery and would request the Court to award the Petitioner a
Judgment for all of his attorney fees incurred in this cause due to her willful failure to comply with
the Tennessee Rules of Civil Procedure both in discovery.
7.
In addition, the Petitioner would request the Court to grant him such other relief as
he may request as sanctions at the hearing of this Motion.

WHEREFORE, the Petitioner prays this Court to order that all information requested in
discovery by the Petitioner to the Respondent in the Interrogatories and Requests for Production of
Documents be immediately and fully responded to by Pamela Moritz and that the Court levy
sanctions against the Respondent for her failure to comply with discovery including but not limited
to reimbursement of his attorney fees and expenses incurred in this cause.
KIMBRLY R. TAYLOR
135 South David Lane
Knoxville, TN 37922
(865) 693-3080
NOTICE TO APPEAR FOR HEARING REGARDING THIS MOTION TO COMPEL
DISCOVERY AND FOR SANCTIONS
TO: PAMELA MORITZ (formerly TULAY)
Reading, Pennsylvania 19606
Please take notice that I shall appear in front of the Honorable Michael W. Moyers,
Chancellor for the Chancery Court of Knox County, Part III, on the 23 day of July, 2008 at 9:30
a.m. to take up the forgoing MOTION TO COMPEL DISCOVERY AND FOR SANCTIONS, and
you are hereby notified to appear on said date at said time if you should wish to contest the
granting of said MOTION.
KIMBERLY R. TAYLOR
OA
I!
I do hereby certify that I have served an exact and true copy of the foregoing MOTION TO
COMPEL DISCOVERY AND FOR SANCTIONS AND NOTICE TO APPEAR FOR HEARING
upon the Respondent, Pamela Moritz (formerly Tulay), by Federal Express and by United States
Mail and addressed to her home address of 2164 Highland Avenue, Reading, Pennsylvania 19606
on this the 11th day ofJuly, 2008.
KfMBERLY RC-TAYLOR
74
PI
I!
T FOR KNOX
N 1P1 F- i
PAMELA MORITZ (then TULAY)
JUL24 2008
Original PlaintifflRespondent,
s/HOWARD G. HOC-,
Docket No. 151759-3
.108q -00 ,-,
V.

FIAT
TO THE CLERK AND MASTER
OF THE CHANCERY COURT
FOR KNOX COUNTY, TENNESSEE
to the granting of the Motion for Injunction filed by Michael Peter Tulay and the
Order granting said Injunction entered by separate Order on this the
2A
ay
of July, 2008, issue
the Temporary Injunction prayed for therein, ordering Pamela Moritz to bring the parties' minor
child Mark Tulay to the Knox County Chancery Court, Part III, located at 400 Main Street, CityCounty Building, Knoxville, Tennessee 37902 at 9:00 a.m. on the l day of August, 2008 for
Father to have co-parenting time with said child with said child and enjoining Pamela Moritz from
interfering with Father's co-parenting time with said child.
1is77'ay of
, 2008.
MIItHAEL W. OERS, CICELLOR
71
STAOF TENE.SSEE, KNOX COTY

CLCERY COURT AT KNOXVILE
INJUNCTION
151759-3
MICHAEL PETER TULAY
PLAINTIFF
VS
To the Sheriff of Knox County - Greeting:

And to PAMELA MORITZ (then TULAY)
.
L.
DEFENDANT
And to all Counselors, Attorneys,, solicitors and Agents, and to
each and every one of them.

Greeting:
'Whereas MICHAEL PETER TTJLAY
has lately filed A
bill of Complaint in said Chancery Court at Knoxville, against you, the said defendant to be relieved touching the matter set forth in said bill in
which it is charged that PAMELA MORITZ (then TULAY)
your actings and doings in the
MICHAEL W. MOYERS
premises are contrary to equity and good conscience, and whereas, the Honorable
Chancellor of the Chancery Court at Knoxville, Tenn., in said State has ordered that an injunction issue, as prayed by complaint
Therefore, in consideration of said fiat, and of the particular matters in said Bill set forth, you, the said defendant and the persons
efore named, and each and every one of you, are hereby strictly commanded and enjoined, under the penalty of a contempt of Court, that
EZA bring the parties' minor child Mark Tulay to the Knox County
jou do absolutely do
Chancery Court, Part III, located at 400 Main Street, CityCounty Building, Knoxville, TN
37902 at 9:00 a.m. on the 1st day of August, 2008 for Father to have Coparenting time
with said child witbj said child and enjoining Pamela Moritz from interfering with Father's
-"
ntil the further order of the said

Witness my hand at
4 th said child.
Court in the premises.

July
this 24 day of
A.D. 2008
CLERK AND MASTER
D.C.
I CERTIFY THAT I SERVE) THE WITHIN INJUNCTION ON THE
DAY OF
Y DELIVERING A COPY OF THE PETITION AND INJUNCTION TO THE DEFENDANT _Pc\Qk
20
()P,
PERSONALLY, OR BY____________________________
I FAILED TO SERVE THE DEFENDANT(S) LISTED DELOW WITHIN THIRTY (30) DAYS AFTER ISSUANCE
CAUSE
SHERIFF
TS\Q -
cz
-Lk rr
7o
-ui1 4
I!

tYt
PAMELA MORITZ (then TULAY),

Original Plaintiff/Respondent,
)
V.
Docket No. 151759-3
)
)
Defendant/Petitioner.
I certify that I served the Order Granting Motion for Injunction, Granting Motion to
Compel, Dismissing Motion for New Trial or for Alteration/Amendment of Judgment, Dismissing
Motion for Relief from Judgments/Orders, and Dismissing Motion for Court to Decline Exercise of
Jurisdiction which was entered on July 24, 2008 upon Pamela Moritz (formerly Tulay) by
delivering a copy of said Order to Pamela Moritz, or by
at the same time that I served the Injunction.
L/
EPUTY SHERIFF'
fU5
Ln
L 1
&
116

Original PlaintifulRespondent,
Docket No. 151759-3
FIAT
TO THE CLERK AND MASTER
OF THE CHANCERY COURT
FOR KNOX COUNTY, TENNESSEE
Pursuant to the Order entered on the
Opty of August, 2008 nunc pro tunc August 1, 2008
arising out of Pamela Moritz failure to comply with the Order entered by this Court on July 24,
2008, issue an Injunction compelling order Pamela Moritz to tender or cause to be tendered Mark
Tulay to Michael Peter Tulay, limiting Pamela Moritz to supervised visitation at Parent Place in
Knoxville, Tennessee pending further order of this Court, and enjoining Pamela Moritz from
interfering with Father's custody and control of Mark Tulay pending further order of this Court.
This Jday of
c/)
, 2008.
W. MOYERS,
79
Child Support Services

507 S Gay Street Suite 400
Knoxville TN 37902
STATE OF TENNESSEE
DEPARTMENT OF HUMAN sERvIcsSVP
26 r
(865) 862-0366
Fax: (865) 862-0403
SEQUO VAR-CONSULTING GROUP
ATrLEBORO,MA 02703-2444
MODIFIED ORDER/NOTICE TO WITHHOLD INCOME FOR CHILD SUPPORT

RE:
MICHAEL TULAY VS. PAMELA MORITZ

FOURTH CIRCUIT Court, Docket No. 151759-3
Knoxville, Knox County Tennessee
TCSES Case: 836172
IMPORTANT NOTICE ***

A. The Attached Order Modifies An Existing Income Assignment Order
The amount shown on the first page of this order is the new total that you should deduct. This new
amount should be substituted for, and not added to the amount you were previously ordered to
deduct for this particular tribunal/case number. This modification does not affect any other deductions
you may have been ordered. to make for any other case(s) involving this same obligor/employee.
[X] If this box is checked, you are no longer required to withhold income for this
employee/obligor for the case specified at the top of the first page of the order. This order to stop
deducting from this employee's/obligor's income only affects the case specified in the attached order. It
does not affect any other deductions you may have been ordered to make for any other cases involving this
same employee/obligor.
B. Remittance Information
With your remittance you must provide the payment Turnaround Document (Employer Obligation Letter)
provided to you by the Department of Human Services, or you must provide all of the following
information.
Docket number
Court identifier
Employee's/Obligor's return address
PLEASE CONTACT THE OFFICE LISTED ABOVE IF YOU HAVE QUESTIONS CONCERNING THIS NOTICE.
IE
[E]ORDERJNOTICE TO WITHHOLD INCOME FOR CHILD SUPPORT
ONOTICE OF AN ORDER TO WITHHOLD INCOME FOR CHILD SUPPORT
I ORIGINAL 0 AMENDED [XI TERMINATION
Date: 9/10/08
State/Tribe/Territory
TENNESSEE
City/Co./DistfReservatlon
KNOX
0 Non-governmental entity or Individual
Case Number 836172/151759-3
RE:
MICHAEL TIJLAY
SEQUOYAH-CONSULTING GROUP
Employer's/Withholder's Address
ATTLEBORO,MA 02703-2444
Employee's/Obligor'iName (Last, First, MI)

167-44-5376
Employee's/Obligor's Social Security Number
1000836172
Employee's/Obligor's Case Identifier
PAMELA MOR1TZ
Employer's/Withholder's Federal EIN Number (if known)
ORDER INFORMATION: This document is based on the support or withholding order from
You are required by law to deduct these amounts from the employee' s/obligor's income until further notice.
0 Per
$
month
- Per month
$
past-due child support - Arrears greater than 12 weeks? Dyes Dno
$
$
0.00 Per
current cash medical support
0.00 Per
0.00 Per
0.00 Per
spousal support
0.00 Per
S
other (specify)
for a total of $00 per MONTH to be forwarded to the payee below.
payment cycle, withhold one of the following amounts:
per weekly pay period.
S
per semimonthly pay period (twice a month).
per biweekly pay period (every two weeks). $
per monthly pay period.
REM17TANCE INFORMATION:
When remitting payment, provide the pay date/date of withholding and the case identifier. If the
employee's/obligor's principal place of employment is Tennessee, begin withholding no later than the first pay period occurring
14 worldn days after the date o19/10/08 5 Send payment within! working days of the pay date/date of withholding. The total withheld
amount, including your fee, may not exceed % of the employee's/obligor's aggregate disposable weekly earnings.
If the employee's/obligor's principal place of employment is not Tennessee. for limitations on withholding, applicable time
requirements, and any allowable employer fees, follow the laws and procedures of the employee's/obligor's principal place of
employment (see 93 and #9, ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS).
Tennessee Child Support
Make check payable to:
If remitting payment by EFL'EDI, call (800)438-6911
Bank routing number:
Use this FIPS code:
Ifthislaairrder fNoUtold:
_______
Print Name 4cz') t4"3
_________________________
Title of Issuing
________________________
Signature
--_-1 Date
______
181 IV-D Agency
0 Court

Bank account number:
Send check to:Receiptinu Unit

P.O. Box 305200
.
Nashville, TN 37229
If this is a Notice of an Order to Withhold:

Print Name____________________
Signature
Date
Attorney 0 Individual
0 Private Entity
0 Attorney with authority under state law to issue o1LriaJce

NOTE: Non-IV-D Attorneys, individuals, and non-governmental entities must submit a Notice of an Order to Withhold and include a
copy of the income withholding order unless, under a state's law, an attorney in that state may issue an income withholding order. In
that case, the attorney may submit an Order/Notice to Withhold and include a copy of the state law authorizing the attorney to issue an
income withholding order/notice.
IMPORTANT: The person completing this form is advised that the information on this form may be shared with the obligor.
ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS

O If checked, you are required to provide a copy of this form to your employee/obligor. If your employee works in a state that is different from
the state that issued this order, a copy must be provided to your employee/obligor even if the box is not checked.
81
I. Priority: Withholding under this Order or Notice has priority over any other legal process under state law (or tribal law, if applicable)
against the same income. If there are federal tax levies in effect, please notify the contact person listed below. (See 10 below.)
2.
Combining Payments: You may combine withheld amounts from more than one employee ' s/obligor' s income in a single payment to
each agency/party requesting withholding. You must, however, separately identify the portion of the single payment that is attributable
to each employee/obligor.
3.
Reporting the Paydate/Date of Withholding: You must report the paydate/date of withholding when sending the payment The
paydate/date of withholding is the date on which the amount was withheld from the employee's wages. You must comply with the law
of the state of the employee's/obligor's principal place of employment with respect to the time periods within which you must
implement the withholding and forward the support payments.
4.
Employee/Obligor with Multiple Support Withholdings: If there is more than one Order or Notice against this employee/obligor and
you are unable to honor all support Orders or Notices due to federal, state, or tribal withholding limits, you must follow the state or tribal
law/procedure of the employee' s/obligor's principal place of employment You must honor all Orders or Notices to the greatest extent
possible. (see 9 below.)
5.
Termination Notification: You must promptly notify the Child Support Enforcement (IV-D) Agency and/or the contact person listed
below when the employee/obligor no longer works for you. Please provide the information requested and return a complete copy of this
Order or Notice to the Child Support Enforcement (TV-D) Agency and/or the contact person listed below. (See 10 below.)
THE EMPLOYEE/OBLIGOR NO LONGER WORKS FOR:
EMPLOYEE'SIOBLIGOR'S NAME:
DATE OF SEPARATION FROM EMPLOYMENT: LAST KNOWN HOME ADDRESS:
NEW EMPLOYER/ADDRESS:
CASE IDENTIFIER:
6.
Lump Sum Payments: You may be required to report and withhold from lump sum payments such as bonuses, commissions, or
severance pay. If you have any questions about lump sum payments, contact the Child Support Enforcement (IV-D) Agency.
7.
Liability: If you have any doubts about the validity of the Order or Notice, contact the agency or person listed below under 10. If you
fail to withhold income as the Order or Notice directs, you are liable for both the accumulated amount you should have withheld from
the employee's/obligor's income and any other penalties set by state or tribal law/procedure.
B.
Anti-discrimination: You are subject to a fine determined under state or tribal law for discharging an employeelobligor from
employment, refusing to employ, or taking disciplinary action against any employec/obligor because of a child support withholding.
9.
Withholding Limits: For state orders, you may not withhold more than the lesser of 1) the amounts allowed by the Federal Consumer
Credit Protection Act (15 U.S.C. 1673(b)); or 2) the amounts allowed by the state of the employee'slobligor's principal place of
employment. The federal limit applies to the aggregate disposable weekly earnings (ADWE). ADWE is the net income left after
making mandatory deductions such as: state, federal, local taxes, Social Security taxes, statutory pension contributions, and Medicare
taxes. The Federal CCPA limit is 50% of the ADWE for child support and alimony, which is increased by 1)10% if the employee does
not support second family; and /or 2) 5% if arrears greater than 12 weeks.
For tribal orders, you may not withhold more than the amounts allowed under the law of the issuing tribe. For tribal employers who
receive a state order, you may not withhold more than the amounts allowed under the law of the state that issued the order.
Tennessee Employers/Payers of Income should refer to the Department's Rule 1240-2-2-05, available on the internet at
httn://www.state.tn.us/sosIrules/1240/1240-02/1240-02-02pdf for state specific information, such as the priority and proration of
payments if multiple Orders/Notices are received for one employee.
Child(ren)'s Names and Additional Information:
TULAY. PETER M.
TULAY. MONICA C.
10.
TULAY, MARK K.
If you or your cmployceiobligor have any questions, contact: CHARISSA E. ROBS

by Fax at
(865) 862-0403
or by Internet at
(1j
by telephone at
(865)
862-0366
0MB 0970-0154
82
two
83
84
vi
ao~
5/1 o//o
7
,1
L
.L
j)
t /
AdcL
O
.'Lc4)
85
Page 1 of 1
03/06/2009 11:28:57

TULAY PAMELA MOPJTZ VS. TULAY MICHAEL PETER
styled case is set for PETITION (PET) at 09:30 AM on
Thursday. 4/9/2009.
MOYERS, MICHAEL W
Name
Address
Trial Notice Date
TAYLOR, KIMBERLY R
04/09/2009
2164 HIGHLAND AVE READING, PA 19606
04/09/2009
PI
.4,
laz
87
Page 1 of 1
04/20/2010 14:20:15

styled case is set for CONTEMPT (CMT) at 09:30 AM
on Tuesday, 6/8/20 10.
MOYERS, MICHAEL W
Name
Address
Trial Notice Date
TAYLOR, KIMBERLY R
06/08/2010
TULAY, PAMELA MORTTZ
06/08/2010
IE
Page 1 of 1
05/10/2010 12:54:08

TULAY PAMELA MO1UTZ VS. TULAY MICHAEL PETER
on Tuesday, 7/27/2010.
MOYERS, MICHAEL W
Name
Address
Trial Notice Date
TAYLOR, KIMBERLY R
07/27/2010
07/27/2010
Page 1 of I
06/29/2010 11:17:36

on Tuesday. 9/14/2010.
MOYERS, MICHAEL W
Name
Address
Trial Notice Date
TAYLOR, KIMBERLY R
09/14/2010
09/14/2010
IF
T
PAMELA MORTIZ TULAY,
JUL 1 9 2010
/4
Original Plaintiff/Respondent
No. 15175*
Mm
WARD G HOGApJ

Original Defendant/Petitioner
NOTICE TO APPEAR FOR PETITION FOR CONTEMPT, FOR MODIFICATION,
AND FOR INJUNCTIVE RELIEF
TO: Pamela Moritz
2164 Highland Ave.
Reading, PA 19606
Please take notice that I shall appear in front of the Honorable Michael W. Moyers,
Chancellor for the Chancery Court of Knox County, on the 14 ' day of September, 2010 at 9:30
a.m. for a hearing in the above referenced cause, and you are hereby notified to appear on said date
at said time. His courtroom is located in the Old Courthouse at 400 Main Street, Knoxville,
Tennessee 37902.
,1nAG
VZ
j-
4ERLYJAYLOR, BP" 01
Attorney for Plaintiff
135 South David Lane
Knoxville, TN 37922
(865) 693-3080
I do hereby certify that I have served an exact and true copy of the foregoing NOTICE TO
APPEAR FOR PETITION FOR CONTEMPT, FOR MODIFICATION, AND FOR
INJUNCTIVE RELIEF upon the Respondent, Pamela Moritz (formerly Tulay), by United
States Mail and addressed to her home address of 2164 Highland Avenue, Reading,
Pennsylvania 19606 on this the 16 T day of July, 2010.
Pamela Moritz
2164 Highland Ave.
Reading, PA 19606
This the I day ofZ1uij ,2010.
'
UMBER
AYLOR
Page 1 of 1
08/16/2010 13:52:42

styled case is set for MOTION FOR DEFAULT
JUDGMENT (MDJ) at 09:30 AM on Tuesday,
8/24/2010,
Name
Address
Trial Notice Date
08/24/2010
TAYLOR, KIMBERLY R
08/24/2010
92
I!
PAMELA ALLISON MORITZ

(formerly PAMELA MORITZ TWLAY),
Original Plaintiff/Petitioner
Docket No. 151759-3
V.

Original Defendant/Respondent
ADA
215-2952
TO:
MICHAEL PETER TIJLAY

9042 Legends Lake Lane
Knoxville, TN 37922
You are hereby summoned and required to serve upon: PAMELA ALLISON MORITZ
Whose address is:
108 South Ann Street
Lancaster, PA 17602
(717)381-0329
a true copy of the answer to the Petition for Modification of Permanent Parenting Plan and
Custody Order which are herewith served upon you, within thirty (30) days after service of
this Summons upon you, exclusive of the day of service. You will file the original with the
Court.
If you fail to do so, judgment by default will be taken against you for the relief demanded in
the complaint.
Issued this 1 64 aday of
day of
j-_4._.'
2012 at
.M.
,20l2.
/..4./a
b*2_
lL
Clerk and Master
zol
po6on PanW6- Horliz 4,94//,J
ptia76
BY: Deputy rk and Master
93
Page 1 of 1
01/22/2013 10:22:37

TULAY PAMELA MORITZ VS. TIJLAY MICHAEL PETER
styled case is set for HEARING (HEM at 09:30 AM on
Thursday. 3/28/2013.
MOYERS, MICHAEL W
-
'.-
Name
Address
Trial Notice Date
03/28/2013
108 S. ANN STREET LANCASTER, PA 17602
03/28/2013
94
RM
Lancaster, PA 17602
(717)381-0329
12U 43
18 January 2013
HOWARD G. HOGAN
The Honorable Michael W. Moyers

Chancellor
Knox County Chancery Court
Suite 125
City County Building
400 Main Street
Knoxville, TN 37902
Re: Docket No. 151759-3
J
Dear Chancellor Moyers,
On December 17, 2012, in accordance with Rule 4 of the Tennessee Rules of Civil
Procedure, service of summons was made upon Respondent/Original Defendant Michael Peter
Tulay of the "Petition for Modification of Permanent Parenting Plan and Custody Order" filed
with this Honorable Court on December 10, 2012.
Thirty (30) days have now passed since service of summons was made with no Answer
being served to the Petitioner to the above-mentioned "Petition for Modification of Permanent
Parenting Plan and Custordy Order" nor having been filed by the Respondent.
Please consider this letter a Motion for Default Judgment in the above-referenced matter.
*es ectrully yours,
kUt
Pamela Allison Moritz, Pro Se

Petitioner/Original Plaintiff
cc: Michael Tulay
95
PI
Page! of!
01/31/2013 15:10:53

TULAY PAMELA MORITZ VS. TIJLAY MICHAEL PETER
styled case is set for MOTION FOR DEFAULT
JUDGMENT (MDJ) at 09:30 AM on Tuesday.
2/26/2013.
Name
Address
Trial Notice Date
02/26/2013
108 S. ANN STREET LANCASTER, PA 17602
02/26/2013
IF
I!

Lancaster, PA 17602
(717)381-0329
O
J'APS1LDVA
EyprsS YAM L
86592O
2.o
ELEE
I
L)S..5.
February% 13
/j \5
2)f2-o3
Howard G. Hogan
Clerk and Master
Knox County Chancery Court
Suite 125
City County Building
400 Main Street
Knoxville, TN 37902
RE: Docket No. 151759-3
Dear Mr. Hogan,
C
/
A copy of "Response to Michael Tulay's 'Petition for Modification of Permanent

Parenting Plan and Custody Order' Filed December 20, 2012" (six pages), along with
related "Affidavit" and "Certificate of Service," are being-telefd-to your office today
for time-stamp and inclusion in court file for the above-mentione&ocket number.
Your assistance in this matter is greatly appreciated.
A I 1.-U'
Sincerely,
3 Te A((/k)''
/2Pamela
Allison Moritz
(formerly Pamela Moritz Tulay),
Enclosures (8 pages)
CO+
;-
k
J-r-i
bo y1e
SE
jru
97
RM
&JM'L~
FILED
Z0I3 KAR28
PAMELA ALLISON MOR1TZ

(formerly PAMELA MORITZ TULAY),
4K 10: %
r10 WARD G HO4J.J
Docket No. 151759-3
V
TO:
MICHAEL PETER TULAY

Knoxville, TN 37922
You are hereby summoned and required to serve upon: PAMELA ALLISON MOR1TZ
Whose address is:
Lancaster, PA 17602
(717)381-0329
a true copy of the answer to the Petition for Revocation of Invalid Parenting Plan and Child
Custody Order of April 9, 2009 is herewith served upon you, within thirty (30) days after
service of this Summons upoa you, exclusive of the day of service. You will file the original
with the Court.
the complaint.
Issued this .4'1dayof

day of
.M.
2013 at
2013.
-'
lk and Master
BY:
4 '-
(----Deputylerk and Master
-"--'-
crhis summons is issued pursuant to Rule 4 of the Tennessee Rules of Civil Procedure.)
4-11
RETURN OF SERVICE
Came to hand on the __9 day of
Executed in full as commanded, Witness
my hand this
57 day of
-,
99
tlIp1
ILED
j
IN THE CHANCERY COURT FOR KNOX COUNTY, Te
_ NNESSEE
tUI3 MAR 28 AM 10" 16
PAMELA ALLISON MOPJTZ

(formerly PAMELA MORITZ TULAY),
HOGAN
Docket No. 151759-3
V.

TO:
MICHAEL PETER TULAY

Knoxville, TN 37922
Whose address is:
Lancaster, PA 17602
(717)381-0329
a true copy of the answer to the Petition for Def]LJ.udefit-Ganting "Petition for
d)rder" which is herewith served
Modification of Permanent Parenting Plan and
upon you, within thirty (30) days after service of this Summons upon you, exclusive of the
day of service. You will file the original with the Court.
the complaint.
Issued this 2Sdayof
day of
/'2
_.M.
jV11L _ Z 7
,2013.
/
ESTCE ctLL.
/ 2152"7
/,D
Clerk and Master
/ 215-292
rv
2013 at
BY:
Deputy Clerk and Master
100
-3
RETURN OF SERVICE
Came to hand on th.D day of___________ 2O

Exeouted in full as conimanded, Witness my hand this
JLday of
-.
101
RM
rnt
0't )oyt)
IN THE CHANCERY COURT FOR KNOX COUNTY. TENNESSEE
zz
PAMELA ALLISON MOR1TZ

(formerly PAMELA MOR1TZ TtJLAY),
Docket No. 151759-3
V.
MICHAEL PETER TIJLAY,

TO:
MICHAEL PETER TULAY

Knoxville, TN 37922
Whose address is:
Lancaster, PA 17602
(717)381-0329
a true copy of the answer to the Petition for Revocation of Invalid Child Support Order and
Judgments of February 27, 2009 and April 9, 2009 which are herewith served upon you,
within thirty (30) days after service of this Summons upon you, exclusive of the day of
service. You will file the original with the Court.
the complaint.
Issued this 2-2 'day of
day of
2013 at
M.
Witness Clerl, and Master of said Court, at office in Knox County, Tennessee, the
Z'
,2013.
LIZ
L) kA
Clerk and Master
BY
e9-
Deputy Clerk and Master

ilrelh
RETURN OF SERVICE
20
Came to hand on the ,) day of
Executed in full as commanded, Withess my hand this 6 I day of

2Oj
_______
-
J5,
J5,r
Shriff
1 03
FILED
IN THE CHANCERY COURT OF KNOX COUNTY, TENNESSEE
AT KNOXVILLE
2913 APR 10 PH 1:22
STATE OF TENNESSEE ex. rel.,
dOWAJib G. HoGj
Docket No. 151759-3
MICHAEL P TULAY
Petitioner! Counter-Respondent
IV-DNo.
V.
001465537
PAMELA A MORITZ
Respondent' Counter-Petitioner
SUMMONS
ittCL\J
TO:
9O
Lict
L'&eL- )
LThj
22
You are hereby summoned to appear before the CHANCERY Court of this county on the
c71tL 10
, 2O/ , at q; C)('),4t1 for a hearing to be held in the

ntter of MICHAEL P TULAY vs PAMELA A MORITZ and bring with you proof of
income. If you fail to do so, a default judgment may be tak
winsxstF
ief
WITNESS: HOWARD H 'GAN, clerk of the CHANCERY Court of KNOX, Tennessee,

this the
1flLJ
H OW
By:
() day of
4O
HOGA
Pursuant to Rule 4.02, T.R.C.P. you must
respond within thirty (30) days of service, or a
default judgment may be entered against you.
(Attorney's Name)
Attorney for the State
(Attorney's Address)
(City, State, Zip)
104
(.
NOTICE
To the Respondent(s):
Based on section 466(a)( 13) of the Social Security Act 42 t S.C.
006( ii)(
vu are
required Lo disclose your Social Security number ic the child support aucnc. The number will
he used under the State's child support enforcrnent prourani
10
locate individuals for the
purposes of establishing paternity and establishing. modifying. and enforcirw supporT ohlivations.
Tennessee law provides a ten thousand dollar, S10.000; persona) properly e;ernpion
from execution or seizure to satisfy a udgmenL If a udgmen should be eni.ered against
VOL
in
this action and you wish to claim property as exempt, you must file a written list, under oath. of
the items you wish to claim as exempt with the clerk of court. The list may he flied at any time
and may be changed by you thereafter as necessary however, unless it is filed before the
judgment becomes final, it will not be effective as to any execution or garnishment issued prior
to the filing of the. list. Certain items are automatically exempt by law and do not need to he
listed. These include items of necessary wearing apparel for yourself and your family and trunks
or other receptacles necessary to contain such apparel, family portraits, the family Bible, and
school books. Should any of these items be seized, you would have the right to recover them. If
you do not understand your exemption right or how to exercise it, you may wish to seeh the
counsel of a lawyer.
I hereby certi' that a copy of this summons has been served upon the respondent by
eti-d-
irn rer.iptg
mS_lO
day of____________________
Summons -
U-
Page 2
105
In
11
State of Tennessee
Department of State
Wm. R. Snodgrass Tower
312 Rosa L. Parks Avenue, 6th Floor
Case Number:
151759-3
70111570000340465053
5/16/2013
Date
Certlfed Number

400 WEST MAIN STREET, SUITE 125
RE: MICHAEL TULAY
VS: PAMELA MORITZ
Dear Clerk:
Enclosed are the following papers In the above styled case:
Original Summons
PAMELA MORITZ
[I]
Sincerely:
Tre Hargett
enclosures
Initials: MMHAW
CC:
SS-4210 (Rev. 12196)
RDA No. 1003
106
PI
AFFIDAVIT
and
ENDORSEMENT
5116/2013
Date
70111570000340465053

RE:
MICHAEL TULAY
VS:
PAMELA MORITZ
Certified Number
I DARLENE LAWRENCE , having been duly authorized by Tie Hargett, Secretary of State
Wednesday. April 24, 2013
That on
I received from the plaintiff the original
PAMELA MORITZ
whose address is:
108 SMITH ANN ST. LANCASTER, PA 17602
Thursday, April 25, 2013
and that on
I mailed by registered or certified returnreceipt mail the certified copies of the Summons and Complaint to the defendant at the above address together with written notice that service was so made. I further make oath that the return
Thursday, May 16. 2013
, and returned to
, Tennessee on Thursday. May 16, 2013
of KNOXVILLE
Tre Hargett
ryoftate
t is 16th
day of May
by
, 2013
7AL1i4w
NOTARY PUBLIC
y NN i LL
\\
! ev
SS-4201 (Rev. 2190)
107
STATE OF TENNESSEE
CHANCERY COURT OF KNOX COUNTY
'Z
Sixth Judicial District
400 Main Avenues Knoxville, Tennessee 37902
C'
1
C
Plainti ff
___
PPc14LA MO
...:'.;.
'
,Defendant
Civil Action No
Sheriff of Knox County, Tennessee

SUMMONS
(Z
?t+&LA MOi
To
A1
I7tLk
%5tjA.?Oi
You are hereby summoned and required to serve upon

Whose addressis: qL42
L4,
.%
WEL_ __T ULr1 '(
371Q
You are hereby summoned to dcfend it civil action filed against you in Chancery Court, Knox County, Tennessee. Your.defcnse roust
be made within thirty (30) days from the date this summons is served upon you. You are directd to file your defense with the clerk.
of the court and send a copy to plaints attorney at the address below. If you fail to do so, judgment by default will be taken against
you for the relief demanded in5omplaint
Issued this
-.
)!P,
C,ei'k and Master
Witness, Howard G. Ho
of said Court, at office in Knoxvill e, Tennessee.
Howard G. Hogan, Cler~ and Muister
Deputy Clerk
NOTICE TO THE DEFENDANT (S):1
Tennessee law provides a ten thousand dollar ($10,000.00) personal property exemption from execution or seizure to satis fy a
judgment If a judgment should be entered against you in this action and you wish to claim property as exempt, you must file a written
listunder oath, of the items you wish to claim as exempt with the clerk of the court The list may be filed at anytime and may be
changed by you theresher as necesaiy howevem unless it is filed before the judgment becomes final, it will not be effective as to any
execution of garnishment issued prior to the filing of theiist. Certain items are automatically exempt by law and do not need to be
listed;- these include items of necessary wearing apparel (clothing) for yourself and your family and trunks of other recepta cles
necessary to contain such apparel, family portraits, the family Bible, and school books. Should any of these items be seized you would
have the right to recover them if you do not understand your exemption right or how to exercise it, you may wish to seek the counsel
of a lawyer. T.CA26-2-1 14.
RETURN ON SERVICE OF SUMMONS

.
20
.
Deputy Sheriff
this s=ons together
with the complaint as follows:
OR ASS I STANCE-CALL
TTY: 86512. 15-9 497
..
Ihereby certify and return that onthe __dayof
ADA
865/215-2952
day of _
Received this
20
.,Iserved
I failed to serve this summons within 30 days after its issuance because
Sheriff-Deputy Sheriff
..
S..
fgW 4PLETE THIS SECTION ON DELIVERY
Complete Items 1, 2, and 3. Also complete

Item 41f Restricted Delivery is desired.
PAMELA MORITZ
108 SMITH ANN ST
LANCASTER, PA 17602
B.
k/4 M
eived by (Printed Name)
0//Atme'ssee
j 9-Dat of Delivery
7Ib1QZIT71S/I3/J2,
D. Is delivery address differeritfmm item 1? D Yes

If YES, enter delivery address below.
D No
3. Service Type
0 Certified Mall D 's ,111
0 Registered
0 Return Receipt for Merchandise
0 Insured Mall
0 C.O.D.
4. Restricted Delivery?
2. Article Number
7011 1570 0003
(Transfer from service /abel) PS Form
3811, February 2004
- Domestic Return Receipt
Pam Fee)
0 Yes
4046 5053
10259502-M-1540I
109
State of Tennessee
Department of State
Wm. R. Snodgrass Tower
151759-3
CaseNumber:
70111570000340465046
5/16/2013
Date
Certifed Number

RE: MICHAEL TULAY
VS: PAMELA MORITZ
Dear Clerk:
Original Summons

PAMELA MORITZ
Sincerely:
Tre Hargett
enclosures
Initials: [MHAW
CC:I
SS-4210 (Rev. 12/96)
RDA No. 1003
110
IM
AFFIDAVIT
and
ENDORSEMENT
5)16/2013
Date
70111570000340465046
Case Number 151759-3

RE:
MICHAEL TULAY
VS:
PAMELA MORITZ
Certified Number
I DARLENE LAWRENCE
having been duly authorized by Tre Hargett, Secretary of State
Wednesday, April 24, 2013
That on
,
PAMELA MORITZ
whose address is:
108 SOUTH ANN ST, LANCASTER, PA 17602

Thursday, April 25. 2013
I mailed by registered or certified returnand that on
receipt mail the certified copies of the Summons and Complaint to the defendant at the above address together with written notice that service was so made. I further make oath that the return
,
Thursday, May 16 2013
of KNOXVILLE
and returned to
Tennessee on Thursday, May 16, 2013
~ &~~
-reta of Stte_&
SM
this 16th
day of May
MIA
.2013
NOTARY PUBLIC
co
"S'
ON
!o.
C,
SS-4201 (Rev. 2190)
111
SECRETARY OF STATE
312 ROSA L PARKS AVENUE
7TH FL. TN TOWER
NASHVILLE TN 37243-1102
615-741-0532
Invoice I Receipt
P
-1
255873
4I24/2o13
Ii
Bill To:
MICHAEL P TULAY PE
6042 LEGENDS LAKE LN
KNOXVILLE TN 37922
CustothriD
900009656
_1_
4:
4124/2013
258849
SUM500
Summons
1577593 MICHAEL TULAY VS PAMELA MORITZ ETAL
$20.001
FOR FURTHER INFORMATION, PLEASE CALL 615-741-1799
00
r'
Check Number
$60.00
3124
$60.00
$6000
STATE OF TENNESSEE
Sixth Judicial District
400 Main Avenue, Knoxville, Tennessee 37902
r
PP
CD
LA(
MtMl
Flaiatiff
PA ELA MO
,Defendant
Civil Action No
StTMIIONS
To
You are hereby summoned and required to serve upon M

6L2
Whose address is
As 4i
L ?
'kE
5ri
-ili.z.
You are hereby summoned to defend a civil action filed against you in Chancery Court, Knox County, Tennessee. Your defense must
be made within thirty (30) days from the date this summons Is served upois you. You are directd to Lie your defense with the clerk.
of the court and send a copy to plaintiff a attorney at the address below. If you fail to do so, judgment by default will be taken against
you for the relief demanded in PC complaint
.
.
Witness, Howard G. HogarL Cleft and Master of said Court, at office in Knoxville, Tennessee.
Howard (3. Hogan, Clernd
..
S.
ter
Deputy Clerk
NOTICE TO ThE DEFENDANT (S):1
>
Tnnnesses law provides a ten thousand dollar ($10,000.00) personal property exemption from execution or seizure to satisfy a
judgment If ajudgxnent should be entered against you in this action and you wish to claim property as exempt, you must file a written
list, under oath, of the items you wish to claim as exempt with the clerk of the court The list may be filed at any time and may be
changed by you thereafter as necesSary, howeyer, unless it is filed before the judgment becomes final, it will not be effective as to any
execution of garnishment issued prior to the filing of thelist. Certain items are automatically exempt by law and do not need to be
listed these include items of necessary wearing apparel (clothing) for yourself and your family and thixil s of other receptacles
necessary to contain such apparel, family porbwits, the family Bible, and school books. Should any of these items be seized you would
have the right to recover them. If you do not understand your exemption right or how to exercise it you may wish to seek the counsel ofa lawyer. T.C.A.26-2-114.
S
.
-RETURN ON SERVICE OF SUMMONS

-, 20 ______.
day of
Received this.
55
S
Deputy Sheriff
I hereby certify and return that on the _______day of
S.
.
...
20
ADA.
FOR ASSSThNCECALL
865/215-2952
TTY: 865/215-2497
_.Iserved
this sunirnons together with the complaint as follows:_______________

I failed to serve this sunimons within 30 days after its issuance because
Sheriff - Deputy Sheriff
.113
Qomplete items 1, 2. and 3. Also complete

item 4 If Restricted Delivery is desired
I Print your name and address on the reverse
Attach this card to the back of the mafipiece,
;~
Ignafure
/2&2"
I
B. ceived by (Printed Name)
-I
ddressee
C. Date of Delivery
D. Is delivery add ress different *om Item 17 D Yes

0 No
if YES, enter delivery address below
p1BLA MOR1TZ
iOS SOUTH ON 17602
LAN CASTE PA
Service Type
0 CertIfied Mall
/z f3.
o Registered
O Insured Mail
4. Res
2. Article Number
(flansfer from seMce label)
PS Form
3811,
February 2004
tfl' 1""
0 Express Mail
0 Return Receipt for
0 C.O.D.
"-
ii 1570 00 Q340 46 S046

Merchandise I
0 Yes
102595-02-M-1540
114
'
PI
I!
State of Tennessee
Department of State
Wm, R. Snodgrass Tower
70111570000340465060
5/16/20 13
Case Number:
151759 - 3
Date
Certifed Number

MICHAEL TULAY
RE:
VS: PAMELA MORITZ
Dear Clerk:
Original Summons
_J
PAMELA MORITZ
Sincerely:
4~ Lt-e
Tre Hargett
enclosures
Initials:
IMMHAW
CC:L
SS-4210 (Rev. 12196)
RDA No. 1003
115
I!
PI
AFFIDAVIT
and
ENDORSEMENT
5/1612013
Date
70111570000340465060

RE:
MICHAEL TULAY
VS:
PAMELA MORITZ
Certified Number
DARLENE LAWRENCE
, having been duly authorized by Tre Hargett, Secretary of State
I
Wednesday, April 24, 2013
That on
PAMELA P4ORITZ
whose address is:

108 SOUTH ANN 5T, LANCASTER, PA 17602
Thursday. April 25, 2013

I mailed by registered or certified returnand that on
receipt mail the certified copies of the Summons and Complaint to the defendant at the above address together with written notice that service was so made. I further make oath that the return
Thursday, May 16, 2013
, and returned to
, Tennessee on Thursday, May 16, 2013
of KNOXVILLE
Tre Hargett

tI(s16th
day of May
(J). !
by
&&" 0VZdAZk,<,
2013
J'
\LL/7-.
NOTARY PUBLIC
TLJI'
-.J
-'-----'.
\.
0
1M
, - ,
-
-sow o'
SS-4201 (Rev. 2/90)
116
STATE OF TENNESSEE
Sth Judicial District

400 Main Avenue., Knoxville, Tennessee 37902
..
..
..
.
:.
'
..
A
rL.
Pk1ELA
.
, Plaintiff
M 6tT?.
,Defendant
Civil Action No
-)

SUMMONS
?MI-A Mo
To
Aui ,
id cou
You are hereby summoned and required to serve upon

.
Whose address is: 56L12
fL\
cfrt
M,
M It-&EL 'T
.J Th-2 3'7IAZ.
You are hereby summoned to defend a civil action filed against you in Chancery Court, Knox County, Tennessee. Your defense must
be made within thirty (30) days from the date this summons is served upon you. You are directed to file your defense with the clerk.
of the court and send a copy to plains attorney at the address below. If you fail to do so,judgrnent by default will be taken against
you for the relief demande4 in he complaint . ... . . .... . .. .
Issued this
dayoft1c,D(,201D
. . . ..
Witness, Howard G. Hoga Clerk anster of said Court, at office in Knoxville, Tennessee.
Howard G Hogan, C1erand Mter
.
NOTICE TO TEE DEFENDANT (S): -..
Deputy Clerk
..
Tennessee law provides a ten thousand dollar (10,000.00) personal property exemption from execution or seizure to satisfy a
judgment If a judgment should be entered against you in this action and you wish to claim property as exempt, you roust file a written
list,, under oath, of the items you wish to claim as exempt with the clerk of the court The list may be filed at any time and may be
changed by you thereafter as necessary however, unless it is fled before the judgment becomes final, it will not be effccth'c as to any
execution of garnishment issued prior to the filing of the list Certain items are automatically exempt by law and do not need to be
listed; these include items of necessary wearing apparel (clothing) for yourself and your family and trunks of other receptacles
necessary to contain such apparel, family portraits, the family Bible, and schoolbooks. Should any of these items be seized you would
have the right to recover them. If you do not understand your exemption right or how to exercise it you may wish to seek the counsel
of a lawyer. T.C.A.26-2-1 14.
.
.
. ..
.
. .
ADA
flJ1 ON SERVICE OF SUMMONS
Received this
day . of
..
, 20
Deputy Sheriff .
day of
I hereby certify and return that on the
this summons together with the complaint as follows:
I failed to serve this summons within 30 days after its issuance because
FOR ASSISTANCE tAft

8651215-2952
..
TTY: 865/215-2497
.
I served
Sheriff- Deputy Sheriff
11 7.
Complete Items 1, 2, and 3. Alo complete

Item 4 If Restricted Dejivety is desired.
I Attach this card to the back of the mailpiece,
B.e elved by (Printed Name)
4iz(r
C. Data of I
ci /3
[4 Is deliveTy address dlfi'erentfmm item 1? 0 Ye
PAMELA MOR1TZ
10 SOUTH ANN ST
LANCASTER, PA 17602
I IT YES, enter delivery address below:
0 No
a Service Type
/zc
2. Article Number(rransfer (torn service labeO
::::?
-
PS Form 3811, February 2004
0 Certified Mail
0 Express Mail
13 eisterad E3 Return, Receipt for Merchandise
fl"
DlnsuredMail
DYes
erc
1311 15
10259 02-M.154o
Complete items 1, 2, L.
. Also complete
item 4 if Restricted Delivery is desired.
so that we can return the card to YOU.
Attach this card to the back of the mailpiece,.
A. Si ture
X V
f)7
B. leceived by (Printed Name)

n
-rZ
V
is deiery add
ES, e
0 Agent
0 Addressee
'
C. Date of Delivery
-
d-ent
b
Pamela A Moritz
108S. Ann St.
Lancaster, PA 17602-431300
--
3.'lcTYP
Certified Mail
0 Express Mail
1!J Registered
Return Receipt for Merchandise
D insured Mail
0 G.O.D.
4. Restricted Delivery? (Extra Fee) -2
PS Form
0 Yes
7010 E780O01 8673 0165

3811,
February 2004

---..
------ -------------------.
102595-02-M1540
-----------
119
21
EN THE CHANCERY COURT FOR KNOX COUNTY, TENNESSEE
PAMELA MORITZ TULAY

Plaintiffs
Vs
No. 151759-3
E20 13-01 528-COA-R3-CV
MICHAEL PETER TULAY

Defendants
SUPPLEMENTAL # 2
CERTIFICATE OF APPELLATE RECORD
I, Howard G. Hogan, Clerk and Master of the Chancery Court of Knox County,
Tennessee, do hereby certify that the following items herewith transmitted to the Court of
Appeals are originals or true and correct copies of all or of the designated papers on file in my
office in the captioned case.
Technical Record attached to this certificate and consisting of 120 pages contained in
one (1) volume.
ihis
J3tf _214 _4s_
2014
H oward C. I-I ngaii

Clerk and Master
Knox County, Tennessee
120

Technical Record-1 PDF

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(

KNOX COUNTY CHANCERY COURT

Michael W. Movers, CHANCELLOR

Pamela Moritz Tula

Michael Peter Tula

JUDGMENT LOWER COURT

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

PAMELA MORTIZ (formerly Tulay)

MICHAEL PETER TULAY

Administrative Order to RedirecL Child

Alias Summons Issued

Cert fled Mail Receipt

Certified Mail Receipt

Certified Mail Receipt

Child Support Services

Child Sunporn Services

Injunction Issued and Executed

Letter Filed - Motion for Default Judgment

Modified Order/Notice to NiLlihoid Income for

Modified Order/NoLice to Njtoo..ricI .ncome for

Motion for Inclusion of Language Reflecting

Motion for Withdrawal of Counsel

Motion to Compel Discovery and for Sanctions

Motion to Permit Withdrawal of Counsel

Non Resident Notice

Notice of Appearance - Faxed

Nonice of Atoorney's Lien

Notice of Trial Calendar Conflict

Notice to Appear for Petition for Contempt,

Order of the Court

Order Permittinq Withdrawal of Counsel

Order/Notice to Withhold Income for Child

PLoof of Publication of Notice in Reading

Report of the Mediator

Show Cause Order

10/ 18/2 002

Summary of No--ices Prinred

Summary of Nor-ices Printed

Summary of Notices Printed

Surrmary.o I Not ces Printed

Summary of Notices Printed

Summary of Notices Printed

Summary of Notices Printed

Summary of Notices Printed

Summary of Polices Printed

Summary of Notices Printed

Summary of Notices Printed

Summary of Notices Printed

Summary of Notices Printed

Summary of Notices Printed

Summons Executed - Secretary of State

Summons Issued and Executed

Summons Issued and Executed

Summons Issued and Executed

Summons Issued and Executed

Summons Issued and Executed

Summons Issued and Executed

Summons Issued and Executed

Supplemental Certificate of Appellate Record

PAMELA MORTIZ (formerly TULAY)

HOWARD G'. HOGAN

MICHAEL PETER TULAY,