RILEY HENRY C ATTORNEYS AT LAW L. Pjiiv Sown St Mr. Robert...

FAX 813-327-8564

JAMES D. HERR? FEATHER SOUND Sown 2325 Uu.jnaN ROAD, SurrE 5 CLMaWA-rnk, FWIUIA 34622 (813) 573-1424

JOHN L. Pjiiv BRENDA D. MAa&H 2325 Finn AVENUE Noam St FrEPsBujkc, FLORiDA 33713 (813) 327-4447

C" RILEY & HENRY

ATTORNEYS AT LAW

co

September 20, 1991

Mr. Robert Paske 455 South Alt. 19, 4t93 Palm Harbor, FL 34683

Dear Bob:

As we discussed the Contempt Hearing for denial of visitation has been set for Friday, 0cQfler 4, 1991 at 10:00 a.m. before-Judge Lnll. Judae Farnell has temporary offices th trie o d courtbuss

at 324 South Fort Harrison, CiearwatfiL.F 1 nririQ.J

I do need a completed Available Monthly Income Affidavit as well as the Financial Statement as soon as possible.

Sincerely,

Brenda D. Marrah

BDM: tal

WILLIAM fl SAYNARO, JR. SARAH M. CHAVES CHARLES W. COPE WILLIAM S. DASKAM IV STEVEN C. DUPRE WILLIAM F. EBSARY, JR. ROY G. HARRELL, JR. MICHAEL J. KEANE MORRIS A. LECOMPTE ERNEST L MASCARA K. PAUL MCGUIRE III S. MICHAEL OSTOW DAVID R. PUNZAI( LEE H. RIGHTMYER LORI L RUTLAND CATHY E. SCHULZ LONNIE L. SIHPSON JOSEPH J. SCROTA, JR. RONALD L. STEPHENSON JULIUS J. ZSCHAU

BAYNARD, HARRELL. MASCARA & OSTOW, P.A. ATTORNEYS AT LAW

28050 US HIGHWAY IS NORTH, SUITE 501 CLEARWATER, FLORIDA 34621 REPLY TO:

(513) 196.2525 0 CITY CENTER SUITE 1202 TELECOPIER: (813) 797.3208 too SECOND AVENUE SOUTH

ST. PETERSBURG, FL 33701 PHONE NUMBER: (813) 823-5000 TELECOPIER: (813) 894-1023 TAMPA NUMBER' 237-5170

0 POST OFFICE BOX ISO ST PETERSBURG, FL 33731

OF COUNSEL

ROBERT P. KAUFMAN (ADMITTED ARIZONA BAR ONLY)

VERNON R. KEISER

DEAN C. HOUK 11904-19841

FILE NO.

November8, 1991

Brenda D. Marrah, Esq. 2325 Fifth Avenue North St. Petersburg, Florida 33713

Re: Paske v. Paske

Dear Ms. Marrah:

My client has advised me that Mr. Paske continues to be delinquent in his child support payments and has made no effort of whatsoever nature to make up any arrearages. Notwithstanding Mr. Paske's employment status, it is apparent that he has the ability to make some payment and demonstrate a reasonable degree of responsibility In supporting his son.

Would you please address this matter with your client. In the absence of payment, I will be compelled to file a Motion for Contempt for non-payment and will further be compelled to seek attorney fees and costs.

I am In hope that our clients can amicably resolve this matter and I look forward to hearing from you at your earliest convenience.

Very truly yours,.

Charles W. Cope

CWC:lk cc: Elizabeth Paske

OWNED IN MV ABSENCE TO AVOID DELAY

Dovio M. WALL ATrORNEY-AT-LAW

OPRES11GE PLACE, SUITE 230 2600 MCCORMICK DRIVE CLEARWATER, FL 34619

(813) 798-6251 FAX (813) 796-0545

September 23, 1993

David J. Kurland, Esq. 850 Clearwater-Largo Road, S.W. Large, Florida 34640

Re: Paske V. Paske

Dear Mr. Kurland:

Enclosed herewith please find a copy of an agreement that was

C executed by Mr. and Mrs. Paske regarding the payment of child support.

Before I set a hearing and request the Court to approve the agreement, I would like to have your client's position as to whether or not it can be done without hearing.

Obviously at this point, paragraph three (3) regarding visitation would be subject to any terms and conditions as set forth by any current Court orders.

Please let me have your response as soon as possible.

Very truly yours, C"

David N. Wall

DNW: j cc: Robert N. Paske

0 CRIMINALLALW TRIAL PRACTICE

DAVID J. KIJRLAND, P. A. ATTORNEY AT LAW

850 CLEARWATER-LARGO ROAD S.W. LARGO, FLORIDA 34640

(813) 461-3555 - FAX (813) 586-2731 PERSONAL INJURY

WRONGFUL DEATH

C

October 6, 1993

David N. Wall, Esquire Prestige Place, Suite 230 2600 McCormick Drive Clearwater, Florida 34619

RE: Paske post-dissolution proceedings; Case No. 90-005283-CI-022

Dear David:

I have reviewed your letter of September 23, 1993, and the attached Agreement on Child Support and Visitation with Mrs. Paske. She explained to me that in December 1992, she entered into the Agreement on Child Support in order to take some of the financial pressure off Mr. Paske while he was changing employment. She feels that he has now had over ten (10) months to make the necessary adjustments and that child support should continue as initially ordered. Up until the commencement of the instant proceeding for modification of visitation, Mrs. Paske was actually rebating child support payments to Mr. Paske that she was receiving from the Income Deduction Order. Accordingly, at this time it will be necessary for you to schedule a hearing to obtain the relief you seek.

Incidentally, I have reviewed the language that you have submitted that is to be included in the Amended Temporary Restraining Order against Mr. Paske, and find it to be acceptable. I was in doubt as to whether you wanted me to prepare an Amended Temporary Restraining Order encompassing your language, or whether it was your intention to prepare your own Order. Please let me know as soon as possible.

Very sincerely,

LAW Q1\F DAVID//. KURLAND

J. Ki*land

DJK:bcm

pc: Mrs. Elizabeth A. Paske

DAVID M. WALL ATTURNJEY-AT-LAW

(71RRFSTIGE PLACE, SUITE 230 2600 MCCORMICK DRIVE CLEARWATER. FL 34619

(813) 799-6251 FAX t913) 796-0545

October 11, 1993

David J. Kurland, Esq. 850 Clearwater-Largo Road, S.W. Largo, Florida 34640

Re: Paske

Dear David:

With respect to your letter of October 6, 1993, in our telephone conversation of approximately that date, it was my understanding that you would be preparing the Amended Temporary Restraining Order.

Please be reminded that a Financial Affidavit on behalf of your client needs to be filed no later than 72 hours prior to the hearing.

Very truly yours,

David M. Wall

DMW:jkl cc: Robert M. Paske

,Th DAVID J. KURLAND, BA.

S

? \05 ..,

CRIMThJAL LAW TRIAL PRACTICE

ATTORNEY AT LAW

850 CLEARWA'ItR.LARGO ROAD SW. LARGO, FLORIDA 34640

(813) 4613555 - FAX (813) 586.2731

October 20, 1993

PERSONAL INJURY WRONGFUL DEATH

David M. Wall, Esquire Prestige Place, Suite 230 2600 McCormick Drive Clearwater, Florida 34619


Dear David:

As discussed by telephone last week, Ms. Paske would be willing to stipulate to a reduction in your client's child support obligation. After we spoke, I calculated Mr. Paske's share of the child support obligation to be $430.40. Ms. Paske's and Mr. Paske's net available income per month is $2,019.62 and $1,779.95, respectively. This totals $3,799.57, which gives rise to a- basic child support obligation for one child in the amount of $793.00. After adding 75% of the day care expense, or $75.00, and the child's share of the health care insurance at $47.75, I arrived at a total need of $915.75. Mr. Paske's percentage is 47%; and, thus, his obligation is $430.40. Ms. Paske would be willing to stipulate to that amount without the necessity of a further hearing. However, we both feel as though some provision should be made for the arrearage, which is substantial and is currently in excess of $6,000.00.

Please review this with your client, and let me know as soon as possible whether this matter can be resolved.

Very

LAW/OFFICE OV DVID J. KURLPJID

J. Kbrland

DJK:bcm

pc: Ms. Elizabeth A. Paske

DAVID M. WALL ATTORNEY-AT-LAW

O966h1G9 PLACE, SUITE 230 2600 MCCDflMICK DRIVE CLEARWATER, FL 34619

(813] 799-6251 FAX (8 13) 796-0545

November 15, 1993


Re: Paske

Dear David:

Discovery is past due with respect to my Request for

O Production. I have scheduled a hearing in this matter, however, if the documents are produced on or before Monday, November 29, 1993, the hearing will be canceled. I think this method would amicably resolve the pending issue regarding my Motion to Compel. If you have any questions please contact me.

Very truly yours,

David H. Wall

DMW: j 1 cc: Robert N. Paske

EXHIBIT #


n ES11GE PLACE. SUITE 230

7aoo MCCDRMCK DRIVE CLEARWATER. FL 34919

(813) 799-6251 FAX (8 13) 796-0545

January 13, 1994


Re: Paske

Dear David:

I would like to be able to discuss with Denis deViaming

O Dr. Smith's report. Can you please let me know as soon as possible, and preferably no later than Tuesday of next week if you would consent.

Very truly yours,

SI DAVtD M. WAU

David M. Wall

DMW: j 1 cc: Robert Paske

MARY ELLEN BORJA Attorney at 14w

FLORIDA BAR BOARD CERTIFIED MARITAL & FAMILY LAW

ACADEMY OF FLORIDA TRIAL LAWYERS

LICENSED TO PRACTICE NEW YORK & FLORIDA

February 4, 1994

DAVID KURLAND, ESQUIRE 850 Clearwater-Largo Road S.W. Largo, Florida 34640

DAVID WALL, ESQUIRE 2605. Enterprise Road, #110 Clearwater, Florida 34619

re: Paske v. Pake

Dear Mr>utcCand and

I am the attorney representing the Guardian Ad Litem Sue Landress, in the above-captioned case. A copy of my Notice of Appearance has been filed in the Court record of this case.

I have noticed that in the Guardian Ad Litem cases, the Guardian Ad Litem's attorney is often omitted from the Certificate of Service and does not regularly receive copies of all pleadings filed.

Please bring this to the attention of your office staff so that they will be sure to include my name and address in the file.

Thank you for your anticipated cooperation.

Veçy truly yours,

MARY ErJkN BaRTh, ESQUIRE

MEB/sea

cc: Sue Landress, Guardian Ad Litem

AMERI-LIFE TOWERS 0 FIRST FLOOR EAST r 536 COUNTRYSIDE BLVD CLEARWATER, FL 346:: (SI? '9.9Q 513 5S539 FAX

DAVID M. WALL ATTORNEY AT-LAW

O PRESTIGE PLACE. SUITE 230 2600 MCCORMICK CRVE CLEARWATER. FL 34619

(8131799-6251 FAX (B 13) 798-0545

March 10, 1994

David J. Kurland, Esq, 850 Clearwater-Largo Road, S.W. Largo, Florida 34640

Re: Paske

Dear David:

Q The Court's order of December 9, 1993, required your client to forthwith provide a copy of her 1992 income tax return. Your Supplemental Response to Respondent/Husband's Request to Produce that was served December 15, 1993, only provided a copy of the medical report issued by Sally Smith, M.D. I have not yet received the tax return as required by the Court's order.

Please provide this return within seven (7) days of the date of this request.

Very-tru1y yours,

David N. Wall

DMW: j 1 cc; Robert Pas]ce

5 DAVID M. WALL ATTORNEY AT-LAW

CPRESTiGE PLACE, SUITE 230

2800 MCCORMICK DRIVE CLEARWATER, FL 34619

(813) 799-6251 FAX (813) 796-0545

March 30, 1994

Robert M. Paske 22 Emerald Bay Drive Oldsmar, FL 34677

Re: Paske

Dear Mr. Paske:

Mr. Rut-land called me on March 29th to advise that his client was intending to request permission from the Court to relocate to

Q the State of California with your child. I don't know anything more and I would anticipate receiving Ieekome sort of paper work from Mr. Kurland's office within the next or so. I will keep you advised.

I

Wall

DMW: j 1

uwvc aw4 5'M15 (c â '6iCL j Q 1 VJ\\4';t

C

DAVID M. WALL ATrORNEY-ATtAW

O PREsTiGE PLACE. SUITE 230 2600 MCCORMICK DRIVE CLEARWATER, FL 34619

(813] 799-6251 FAX (8 13) 796-0545

March 30, 1994

David J. Kurland, Esq. 850 ..Ctearwater-Largo Road, S.W Largo, Florida 34640

Re: Paske

Dear David:

Enclosed herewith please find a Form 4506 Request for Copy of Tax Form. Would you please have Ms. Paske, or your office fill in the appropriate information, have Ms. Paske sign and date and return the form to my office in the enclosed envelope. I would expect to have this back within one (1) week's time based on the lengthy delay in just now having been advised that no tax return is available.

In light of the duration of this litigation, I will be requesting a copy of Ms. Paske's W-2 Statement for 1993, as well as a copy of her income tax return for 1993. Maybe you could ask her a head of time to keep an extra copy of this year's return together with a copy of her W-2 statement.

Very truly yours,

David N. Wall

DMW: jkl enclosure (specified) cc: Robert Paske

i i&cD \jt5

IHR(L

H -- CRIMINAL LAW flIAL PRACTICE

DAVID J. KURLAND, P.A. AflOENEY AT LAW

850 CLEARWAThR.LARGO ROAD S.W. LARGO, FLORIDA 34640

(813) 461-3555 - FAX (813) 586-2731

April 5, 1994

PERSONAL INJURY WRONGFUL DEATh

David M. Wall, Esquire Suite 230, Prestige Place 2600 McCormick Drive Clear-water, Florida 34619


Dear David:

Pursuant to our telephone conversation of last week, I have forwarded to you, under separate cover, a copy of an Amendment to Petition to Modify Order of Final Judgment. This will confirm our agreement that you will respond to the Amendment to Petition

Q without the necessity of my filing a motion to amend pleadings. This will further confirm that you will respond to this amendment within 20 days from the date of filing. I appreciate your eliminating unnecessary pleadings and reducing delay.

With respect to your request to produce Ms. Paske's income tax return, she reports that after a diligent search she is unable to find and produce this document. She informs me that she has no objection to your sending directly to the Internal Revenue Service for this return; and, accordingly, I will forward to Ms. Paske for her completion and signature the Request for Copy of Tax Form that you have furnished me.

Very sinpely,

LAW OZF/LCE 01,1 DAWD J. KURLAND

J. ,t(urland

DJK:bcm

pc: Ms. Elizabeth A. Paske

UJ u-c? cL

01PRES11GE PLACE. SUITE 230 2600 MCCORMICK DRIVE CLEARWATER, FL 34619


(B1 33 799-8251 FAX [813] 798-0545

April 18, 1994


Re: Paske

Dear David:

In review of my file I am reminded the Court's order of December 9, 1993, has already dealt with the issue of the 1992 Income Tax Return. The Court order indicates the former husband's Motion to Compel is granted and the Petitioner shall forthwith provide a copy of 1992 Income Tax Return. The burden therefore is upon Mrs. Paske to produce this return immediately. If necessary, I have returned to you the request form executed by Mrs. Paske.

With respect to the 1993 return, I was only furnished page (2) two. Could you please have Mrs. Paske provide page (1) one as soon as possible. Apparently a Mr. Pease (785-7460) prepared at least the 1993 return. You might want to check with Mr. Pease to see if he prepared the 1992 return.

Very truly yours,

David M. Wall

DNW: jkl enclosure (specified) cc: Robert Paske

DAVID M. WALL ATTIThEY AT LAW

PRESTIGE PLACE, SUflE 2 2600 MCCORMICK DRIVE

-, CLEAJRWATER. FL 34619

[813)799-8251 FAX (813) 788.0545

May 6, 1994

Nary Ellen Borja, Esq. Anteri-Life Towers - First Floor East 2536 Countryside Blvd Clearwater, FL 34623

Re: Paske

Dear Mary Ellen:

The above reference matter involves Sue Landress and you as

Q the attorney for the Guardian ad Litem. Mr. Paske as requested by Sue Landress has had one appointment with the psychologist, Dr. Kroungold. Dr. Kroungold is requesting a copy of the MRS Final Report of Investigation. He requested that Mr. Paske provide this, however, I have told Mr. Paske that in my opinion the transmittal of any such report should come from the Guardian ad Litem and not from Mr. Paske.

Can you please contact Sue Landress and ask her to get in touch with Dr. Kroungold and make whatever arrangements are necessary so that Dr. Kroungold can reviey the MRS Report. I thank you for your time and cooperation in this, regard.

Very t1ruJy-yours,

M. Wall

DMW: j k 1 cc; Robert Paske

PSYCHOLOGICAL SERVICES • Harbor Oaks Medical Center

fl 1106 Druid Road South, Suite 201

Clearwater, Florida 34616 442-6007

FAX 441-3981

LYNDA OUR VITZ, Ph. D. MITCHELL H. KACUNGOLD, Ph. 0. MARY M. CULM, B.A. ADULT AND GERIATRIC PSYCHOLOGY

CHILD AND ADULT PSYCHOLOGY

EDUCATIONAL SERVICES

License N PY0003166

License N PY0002366

October 18, 1994

GONFIDENTII\L David M. Wall, Esquire 2600 McCormick Dr. Clearwater, FL 34619

Re: Paske family

Dear Mr. Wall:

Enclosed is a copy of the recent diagnostic observations of Mr. Paske interacting with his 6 year old son, Joey.

I hope this information is helpful in your work with this family. Please feel free to contact me if I can be of further assistance.

Sincerely,

Mitchell Kroungold, Ph.D. Licensed Psychologist

MX / dv S

Enclosure

DAVID M. WALL AT1DAMY AT LAW

PRES11GE PLACE. SLIME 230 2600 MCCORMICK ORME CLEARWATER. FL 34619

[8133 799-6251 FAX (813) 796-0545

November 10, 1994


Re: Paske

Dear David:

This will confirm our telephone conversation of yesterday morning only to remind you that I would very much appreciate a copy of the deposition of Dr. French. Could you please furnish me a copy of this deposition as soon as possible along with a bill for any appropriate copying charges.

Very truly yours,

Cj L{D P

David N. Wall

0MW: jkl cc: Robert Paske

DAVID M. WALL ATWF?'EY AT LAW

PRES11GE PLACE. sUrrE 230 2600 MCCORMICK DRIVE CLEAPWATER, FL 34619

(813) 799-6251 FAX (8 13) 79640545

November 10, 1994

The Hon. James R. Case Circuit Judge 315 court Street Clearwater, FL 34616

Re: Paske

Dear Judge Case:

Attached hereto please find my Motion to Compel with respect

Q to production of documents in the above referenced matter. I can not represent this matter to be an emergency, however, I would like to have this issue resolved as expeditiously as possible. Can you please have your Judicial Assistant contact my office perhaps for a phone conference between counsel or for some immediate time that might be available for counsel to attend a hearing.

Very truly yours,

David M. Wall

DMW: j k 1 cc: David J. Kurland, Esq.

Nary Ellen Borja, Esq.

H

MARY ELLEN BORJA Attorne!yatLaw

FLORIDA BAR BOARD CERTIFIED 10 - MARITAL & FAMILY LAW

ACADEMY OF FLORIDA

November 29, 1994 TRIAL LAWYERS

TO PRACTICE NEW YORK & FLORIDA

David N. Wall, Esquire 2600 McCormick Drive Suite 230 Clearwater, FL 34619

David J. Kurland, Esquire 850 Clearwater-Largo Road, S.W. Largo, FL 34640

RE: PASKE V PASKE

Gentlemen:

Since the pending litigation is not a Chapter 39 proceeding in which the file would be sealed, the Guardian ad Litem has a great deal of concern regarding the testimony that will be elicited and evidence that will be presented at trial, all of which will be available for public inspection and might be read by the child at a later date. This could have the effect of undoing the unification efforts and causing him unnecessary pain in his teenage or adult years.

Before everyone undergoes the emotional stress, and financial drain of a two-day trial, the Guardian ad Litem earnestly proposes the following to you for your consideration as a relatively amicable settlement of the issues presented. We hope you and your client will give it thoughtful consideration, and, in Joey's best interest, agree to the following:

1. Allow the mother and child to move to California on a permanent basis.

2. Allow the mother to have sole parental responsibility until such time as the child's therapist and the father's therapist agree that shared parenting no longer poses a danger to the child's well being.

3. Authorize an exchange of information between the child's therapist and the father's therapist regarding progress in therapy, problems, reunification efforts and other information as deemed appropriate by the therapists.

4. Allow the child's therapist and the father's therapist to have copies of Mitch Kroungold's, Ph.D., reports and the Guardian ad Litem's reports and other information they deem necessary to understand the psychological functioning of the child and father,

AMERI-LIFE TOWERS • FIRST FLOOR EAST • 2536 COUNTRYSIDE BLVD. N CLEARWATER, FL 34623 (813) 791-9911 • (813) 725-5539 FAX

and to understand the nature of the allegations and history of the

C) case. 5. Allow the child's therapist to be considered the case

manager and to have decision-making ability when the father's and child's therapists are in conflict as the child's best interests needs to take priority over the parent's best interests.

6. Exchange the names, addresses and telephone numbers of the father's therapists and child's therapists within 30 days of the signing of the stipulation.

The Mother agrees to:

1. Keep the father informed as to Joey's extra curricular activities such as sports, performances and participation in Scouting-type activities and provide the father with photographs of Joey in a timely manner but not less than every three months.

2. Send the father copies of the child's school report cards, progress reports, pictures and placement in a timely manner but no less than every four months.

3. Keep the father informed of the child's medical history including immediate notification of serious emergency medical treatment and all hospitalizations.

4. Have the child in therapy as recommended by Gail Azar and to follow all recommendations of the child's therapist.

5. Cooperate with reunification efforts as long as they are recommended by the child's therapist.

6. Have the child available for reunification therapy as recommended by the child's therapist and to cooperate with the father in scheduling such sessions.

7. Follow the child's therapist's recommendations as to visitation and as to written and telephonic communication between the father and child.

8. Refrain from alienating the child from the father by any behaviors or verbalizations.

The Father agrees to:

1. Cooperate with the child's therapist regarding reunification.

2. Attend and successfully complete parenting classes.

3. Communicate with the child's therapist and to follow the child's therapist's recommendations as to frequency and types of communication.

4. Attend mental health therapy with a Court-approved

fl therapist to deal with issues of sexually inappropriate behavior, child development, impulse control, anger management, awareness of feelings, insight, judgment, alcohol abuse, parenting skills and other areas as deemed necessary by the therapist until released by the therapist for clinically satisfactory reasons. (If the father is released by the therapist because of personality problems, lack of payment, failure to follow recommendations or failure to cooperate or any other reason not related to an improvement in the father's mental health, emotional status, then the father agrees to attend therapy with another therapist as approved by the Court or as recommended by the previous therapist.)

5. Cooperate fully with his therapist and follow recommendations of the therapist.

6. Cooperate fully with the child's therapist and to follow the child's therapist's recommendations with regard to visitations, communication and reunifications.

7. Travel to the child's therapist for reunification, visits and therapy once such a procedure is approved by the child's and father's therapists.

8. Communicate with the child's school, medical practitioners, associates and the mother and stepfather, following

Q the recommendations of the child's and father's therapists only.

9. Refrain from any type of harassment of the child, mother, stepfather, child's therapist or schools.

Vey truly yours,

MARY ZEN BORJA, ESQ. MEB/cm

cc: Guardian ad Litem

DAVID J. KURLAND ATrORNEY AT LAW

850 CLEARWATER-LARGO ROAD S.W. LARGO, FLORMA 34640

TRIAL PRACTICE (813) 461.3555 - FAX (813) 586.2731 WRONGFUL DEATH

January 25, 1995

David M. Wall, Esquire Suite 230, Prestige Place 2600 McCormick Drive Clearwater, Florida 34619


Dear David:

As we discussed by phone on January 19th, enclosed please find a copy of the court reporter's bill for her attendance at the final hearing in December of 1994. Prior to the commencement of the hearing, Mr. Paske suggested, and I agreed, that each party would be responsible for one-half (½) of the payment of this bill. I

O ordered the court reporter, and they are looking to me for payment. Accordingly, please have Mr. Paske remit to me, at his earliest convenience, one-half of the amount of the bill, or $211.87.

Enclosed is a recent photograph of Joey Paske, together with a sample of his school work. Mrs. Pratt sent it to me to send to Mr. Paske since she did not have his current address. I have now mailed her a copy of the Motion for Contempt, which carries with it Mr. Paske's new home address and telephone number; and she, accordingly, will send all further correspondence directly to him.

Thank you for your cooperation.

Very sincerely,

LAW OFFICE OF DAVJ.

David ci;

DJK:bcnt

Enclosures - S

pc: Mrs. Elizabeth Pratt

DAVID J. KURLAND 1 ATTORNEYATLAW

850 CIEARWATER-LARGO ROAD S,W. (\ iaw LARGO, FLORIDA 34640 PEB&)NAL UURY

TRIAL PRACtICE (813) 4614555 - FAX (813) 586-2731 WRONGFUL DEATH

February 14, 1995

Mr. Robert H. Paske 22 Emerald Bay Drive Oldsmar, Florida 34677

Dear Mr. Paske:

The name, address and telephone number of Joey's counselor in California are: Sol Leopold, M.S.W., Ph.D., 3250 Lomita Boulevard, #308, Torrance, California 90505; (310) 539-1434.

Joey's address in the State of California is: 803 South Juanita, Redondo Beach, California 90277.

Very sincerely,

DJK:bcm

pc: Mrs. Liz Pratt

David I. Kurland, Esq. (

) 850 Clearwater-Largo Rd. SW Largo, Fl, 34640

February 27, 1995

David,

On February 15, 19951 moved. My new address is:

Robert M. Paske 5265 East Bay Drive Unit 712 Clearwater, FL 34640 Home Phone 813-524-3859

My work phone number has not changed.

Thank you.

sinc!~~ 79 e 141,ze, Robert M. Paske

(

CRMINa LAW UUAL PRACTICE

DAVID: J. fl:tLAND AflOBNEY AT LAW

850 CLEARWAtR-LARGO ROAD S.W. LARGO, FLORIDA 34640

(813) 4613555 - FAX (813) 5864731

March 27, 1995

PERSONAL WOURY WRONGFUL DEATH

Mr. Robert M. Paske 5265 East Bay Drive, Unit #712 Clearwater, Florida 34624

Dear Mr. Paske:

Enclosed please find a copy of a proposed Order Governing Former Husband's Motion for Contempt, which, I believe, accurately reflects the Court's ruling at the hearing on the Moton on March 21, 1995. If you have any objections to either content or form, kindly notify me within five (5) working days of the date of this letter. If there are no objections made by April 3, 1995, I will forward the proposed Order to Judge Case for signature, and provide for a conformed copy to be furnished to you.

Very sincerely,

DJK:bciu

Enclosure - 1 page

0 03/30/95 co f

David,

Here is the wording I would like added to the order:

In addition, the court specifically states, in the future, the Petitioner shall refrain in any way from attempts to restrict access to the minor child's school from the Respondent. This includes, but is not limited to parent/teacher conferences, access to and a copy of the minor child's file, and copies of schoolwork to be sent periodically.

Call me at 588-6461 if you have any problem with it.

Thank you.

M ON

IC

1*

Robert M. Paske 5265 East Bay #712

Clearwater, Florida 34624 (813)588-6461 - (813)524-3859

May 9, 1995

Mr. David J. Kurland 850 Clearwater-Largo Road SW Largo, Florida 34640

Dear Mr. Kurland:

Enclosed please find a copy of a proposed Order Governing Former Husbands Motion to Allow Telephonic Parent/Teacher Conferences, which, I believe, accurately reflects the Court's ruling at the hearing on the Motion on May 8, 1995. If you have any objections to either content or form, kindly notify me within three (3) working days of the date of this letter. I have already forwarded the proposed Order to Judge Case for signature, and he will sign it unless objections are made known within that time period.

Very$i)lcerely,

Robert M. Pasl(e

-2

Robert M. Paske 5265 East Bay #712

Clearwater, Florida 34624 (813)588-6461 - (813)524-3859

July 31, 1995

David J. Kurland Esq. 850 Clearwater-Largo Road, S. W. Largo, FL 34640

Mr. Kurland:

You have indicated you would like the following information, so here it is:

Dr. Robert G. Harrison PY0002267 901 N. Hercules Ave (813)441-4579

I started seeing him on or about January 23, 1995. I have gone once per week since that time.

0 If you require any more information, please call or write.

Sincerely,

Robert M. Paske

r1pil Attorney at Law

FLORIDA BAR BOARD CIiRflFIEI) MARITAL AND FAMILY LAW

ALSO LICENSED 10 PRACTICE IN THE STATE OF NEW YORK

August 17, 1995

Robert N. Paske, Pro Se 22 Emerald Bay Drive Oldsmar, Florida 34677 WROP06 ADft€SS

David Kurland, Esq. 850 Clearwater-Largo Road S.W. Largo, Fl. 34640

re: Paske v. Paske

Dear Messrs. paske and Kurland:

Sue Landress advises me that she has not yet received any records from the therapists. Please investigate the delay. If the records are not provided to Sue Landress right away, she will not have the ability to assess them and prepare for a September hearing.

I would appreciate your prompt attention to this matter.

V ry truly yours,

MARY EN BORcJA, ES

MEB: sr

cc: Sue Landress,:G.A.L.

r c4tek t(LtMlk VVI (AJ

rvec frO&- it

fiispJ Au&fl L

AMERI-LIFE TOWERS • FIRST FLOOR EAST I 2536 COUNTRYSIDE BLVD. U CLEARWATER, FL 3423 (813)791.9911 • (813)725-5539FAX

NOTICE OF PRODUCTION FROM NON-PARTY

TO: David J. Kurland, Esq. 850 Clearwater-Largo Road, SW Largo, FL 34640

Mary Ellen Borja, Esq. Amen-Life Towers, 1st floor E 2536 Countryside Boulevard Clearwater, FL 34623

YOU ARE HEREBY NOTIFIED that after ten (10) days from the date of service of this notice, the undersigned will apply to the Clerk of the Court for issuance of the attached Subpoena directed to the following: GTE of Florida, 201 N. Franklin St., Tampa, FL 33602, who are not parties to this action to produce the items listed at the time and place specified in said subpoena.

I HEREBY CERTIFY that on this 21st day of November, 1995, a copy of this Notice (with attachments) was served by regular US Mail to the above named addressees.

Robert M. Paske 5265 East Bay Drive #712 Clearwater, FL 34624 (813)524-3859

-r

EN

DAVID J. KURLAND ATTORNEY AT LAW

850 CLEARWATER.LARGO ROAD S.W.

CRIMINAL LAW LARGO. FLORIDA 34640 PERSONAL ThURY

TRaLPIkACnCE 813) 461.3555 - FAX (813) 586-2731 WRONGFUL DEATH

April, 1996

The Honorable James R. Case Pinellas County Courthouse" 315 Court Street, Room 410-- Clearwater, Florida 34616


Dear Judge Case:

Enclosed please find the original Motion for Referral to General Master and the

() original and three (3) copies of the Order of Referral to General Master.

If the proposed Order meets with the Court's approval, kindly execute and have your judicial assistant distribute copies in the enclosed stamped, self-addressed envelopes.

Very sincerely,

LAW OFFICE OF DAVID J. KURLAND

Sheila Skellie, Esquire

SKS :tms Enclosure

pc: Mr. Robert M. Paske

- I

j6iT C April 10, 1996

Mr. Kurland,

Enclosed you will find a copy of my paycheck. Also enclosed you will find a copy of the letter you sent Mr. Wall the last time we went through all this.

The first thing I want to say is that last time we went through this one of the reasons I did not agree to it was because I knew she would understate her income on her financial affidavit - and she did. Enclosed you will see her financial affidavit and her W-2 form.

The next thing I want to say is that when we divorced, she agreed to: 1. Sell the windsurfer and split the money. (Well, she sold it! .- she just kinda forgot to split the money.) 2. She would split the Christmas Ornaments (some which were very sentimental) with me. (Never did.) 3. She would split the camcorder with me. (Never did.)

Despite the fact I am financially worse off now than when we made the agreement - and the agreement says I need to be better off to change it - I would be willing to stipulate to $400/month plus $100/month to pay arrearages. I believe this should be very close to the guidelines - and more than fair considering the last few years. This arrangement would come close to paying off all arrearages by the time Joey is 18.

One other item of business - I still owe you for the court reporting for the trial. I still have to pay Mr Wall his last payment this month and he will be paid off. The next month (May) you will get your money as I promised. I said from the beginning I would pay you, and I always was going to, but as I told Mr. Wall a long time ago, lie gets paid first, you next. I believe (lie amount is approximately $200.

Please review this with your client, and let me know as soon as possible whether this matter can be resolved. Thank you.

Robert M. aske

D*ll J. KUiI.: ATTORNEYAT14AW

850 CLEM W LARf. ROD S.W.

CRW2AL LAW LM!Qp nORMA 31040 PERKJNAL 2URY

flIM. PRACncS (81) 461-3555 - FAX (813) 6-2731 WRONQ'UL MATH

May 24, 1996

Robert M. Paske 1600 - 1st Street, Unit "C" Indian Rocks Beach, FL 33785


Dear Mr. Paske:

In response to your letter dated April 10, 1996, my client has rejected your proposed offer of $400.00 per month plus $100.00 toward the arrearage. Unfortunately, that proposal would only slightly improve the arrearage situation. By the time Joey was eighteen, the arrearage would still be well over $20,000.00. However, my client would propose that you pay $500.00 per month toward your actual child support obligation and $150.00 per month toward the arrearage. In this way, the arrearage would only be approximately $6,000.00 when Joey turned eighteen. As an alternative, Mrs. Pratt would also accept $500.00 per month toward the child support and $100.00 per month on the arrearage with annual payments of $1,000.00 which could be paid on a semi-annual or quarterly basis. Here, the arrearage would only be approximately $1,600.00 by the time Joey reached eighteen. Please advise whether you would agree to either of these proposals.

Enclosed please find an Objection to your Request to Produce served upon my client. I would also remind you that a response to the Request to Produce which we served upon you is eighteen days over due. Please provide the documentation as soon as possible as we require it to prepare for the upcoming hearing regarding this matter. However, if we could reach a settlement, we could forego the legal work and court time. Thank you.

Very sincerely,


Sheila Skellie, Esquire

SKS:tms

pc: Mrs. Elizabeth Pratt

May 29, 1996

Mr. Kurland,

I can see with the numbers you quote in your letter to me, you misunderstood my offer

My offer includes REDUCING the child support to $400/month - a much more fair amount as shown by your own calculations on October 20, 1993 stating my child support obligation should be $430.40. My offer also includes $100 per month payment to go towards arrearages. In that way the full arrearage would almost be paid off in full by the time Joey was 18.

I am willing to change my offer slightly - to $120 per month towards arrearages so the full arrearage WOULD be paid off by the time Joey is 18.

I have been paying an amount of $580 for years now, when it should have been only $430 - by your own calculations.

Please find enclosed my motion to modify child support. Please consider my earlier request to produce a request to produce for this motion of reduction.

Please review this letter with your client, and let me know whether this matter can be resolved without having to go to court on the 21 and in the future. Thank you.

Sineerea,

4 lie, 4 Robert M. Paske

PS...: J..KURLAND AOR1flYATLAW

850 CLEARWATRR#LAWQ ROAD S.W.

Ca41NAL LAW LARGO, FLORII)A 34640 TRIAL PRACTICE (813) 461.3fl5 - FAX (8>13) 586-2731

June 14, 1996

PRSONL INJL]Y WRON*tn. DEATh

Robert M. Paske 1600 - 1st Street, Unit "C" Indian Rocks Beach, FL 33785


Dear Mr. Paske:

In response to your letter dated May 29, 1996, my client has rejected your proposed offer of $400.00 per month plus $100.00 toward the arrearage. Please be advised that the calculations made on October 20, 1993 no longer apply since the income figures used in those calculations no longer exist. My client, however, would propose that the child support obligation be reduced to $500.00 terminating at the appropriate time and that you pay an additional $100.00 per month toward the arrearage until it is paid in full. Please advise whether you would agree to this proposal before the hearing on June 21, 1996.

Also enclosed please find copies of the Former Wife's Motion to Strike, Motion to Compel and Amended Notice of Hearing. I would be glad to forego the Motion to Compel if you comply with the document production before close of business day Wednesday, June 19, 1996. Thank you.

Very sincerely,


cheila Skeffie, Esquire

SKS :tms PC: Mrs. Elizabeth Pratt

DAVID J. KURLAND ATIDRFEY AT LAW

850 CLtARWAThR.LARCJO ROAD &W. QUMINAL LAW

IARGO, FLORIDA 34640 MALPRACTICE

(813) 461-3555 - FAX (813) 586-2731

June 28, 1996 -.

r David M. Wall, Esquire 2600 McCormick Drive, Suite 230 Clearwater, Florida 34619

RE: Paske post-dissolution proceedings; Case No. 90-005283-C1-022

Dear Mr. Wall:

Enclosed please find the original proposed Stipulation of the Parties for Modification of Child Support and Order together with the new Order Directing Payments, Income Deduction Order and Memorandum of Clerk. As you may notice, I did not include your name in the stipulation as I did not want to place you in a position of being attorney of record. Also, I have stated that the commencement date of this stipulation should be July 1, 1996. I am sure that the Clerk of Court will make any adjustments necessary at the appropriate time. Please advise whether you have any objections as to form and content. If not, please have Mr. Paske sign and return to this office as soon as possible. I will forward it on to Judge Case upon receipt. It would be helpful if Mr. Paske could fill in all personal information which is missing on the forms. I can revise them before sending them to the Court. Thank you for your cooperation in this regard.

Very sincerely,


a, Sheila Skellie, Esquire

SKS :tms Enclosures

PERaJ,qAL 1I'QURY WRONG*tJL DEATH

fl CRDAINAL LAW ThMLPRACflCE

DAVID J. KURLAND AVIORNEY AT LAW

850 CLEARWAThR-LARGO ROAD &W. LARGO, FLORIDA 34640

(813) 4613555 - FAX (813) 586-2731

October 8, 1996

Joe D. Lovelace, Esquire General Master. Pinellas County Courthouse 315 Court Street, Room 427 Clearwater, Florida 34616


Dear Mr. Lovelace:

Enclosed please find the original and two copies of the proposed Report and Recommendation of General Master and Order Approving Report and Recommendation

CD regarding the above referenced matter which accurately reflects your decision of September 26, 1996. I had previously sent a copy of this proposed report to the Former Husband for comment but he has hot responded.

If the proposed Report meets with your approval, please sign and have your assistant forward it to the Court for entry. Self-addressed, postage paid envelopes have been included for convenience in mailing conformed copies.

Thank you for your attention to this matter.

Very sincerely,

LAW OFFICE OF DAVID J. KIJRLAND

_zt Sheila Skellie, Esquire

SKS :tms pc: Mr. Robert Paske'-'7

- ........ .. ... .. . . . . ---.-. .



(813) 461-3555 - FAX (813) 586-2731 (1R1M1NAL LAW

TRIAL PRACTICE PERSONAL INJURY

WRONGFUL DEATH

January 6, 1997

Robert M. Paske 1600 - 1st Street, Unit "C' Indian Rocks Beach, FL 33785

RE: Paske post-dissolution proceedings; Case No. 90-005283-Cl-022

Dear Mr. Paske:

Enclosed please find a copy of a proposed Adopting Stipulation to Modify Visitation and Support, embodying Judge Case's ruling on December 6, 1996. Since I have been

CD unable to contact you by telephone to determine if there is a fax machine to which I may fax this proposed Order for your consideration, I must rely on the mail. Please review; and if acceptable, contact me as soon as possible so that I may forward this Order to Judge Case for his signature.

Very sincerely,


J.

DJK:bcm

Enclosures - 2 pages

(T)RIMINAL LAW TRIAL PRACTICE



(813) 461-3555 - FAX (813) 586-2731

January 10, 1997

PERSONAL INJURY WRONGFUL DEATH

Hon. James R. Ca~ Circuit Judge Room #410, P)téllas County Courthouse 315 Court kfet Clearwatf, Florida 34616-5192


Dear Judge Case:

Enclosed please find an original and three (3) copies of a proposed Order Adopting Stipulation to Modify Visitation and Support, which, I believe, accurately reflects the

(Th Court's ruling on the Motion to Adopt Stipulation to Modify Visitation and Support that was heard by the Court on Friday, December 6, 1996. I have provided a copy of the proposed Order to Mr. Paske, who has informed my office that he has no objection to it.

If the Order meets with your Honor's approval, as to both content and form, kindly execute and distribute copies in the enclosed stamped, self -addressed envelopes.

Very sincerely,

LAW OFFICE OF DAVID J. KtJRLAND

Q— Z J/Kurland

DJK:bcm

Enclosures - 8 pages and 2 stamped, self-addressed envelopes

PC: /Robert Mark Paske, Respondent/Former Husband

Aug-09-99 12:59P A. Dean Hoolihan, P.A. 727-726-0371

P.01

Sw 0/ftc.: 0/

A. DEAN HOOLIHAN, P.A.

2790 Sunset Point Road Clearwater, FL 33759

Real cC sicie Saw Coqnnie & un)7ess Sw Telephone: (727) 796-1201

J%nonaulnfry & &nn4J?Jea/A

2FanYaf&9wr4.&w

Fax: (727) 726-0371

&,* 731, & 73L2/.

August 6, 1999

FACSIMILE TRANSMITTAL (727)586.2731

David Kurland, Esquire 850 Clearwater-Largo Rd., SW Largo, FL 33770-4470

FACSIMILE TRANSMITTAL (727) 796-0545

David M. Wall, Esquire 2600 McCormick Dr., Suite 230 Clearwater, FL 33759-1040

Re: Paske Mediation

Dear Mr. Kurland and Mr. Wall:

I understand you have scheduled mediation of the referenced matter for 9:00 a.m. on Tuesday, September 7, 1999 at my office. The mediation rate is $150.00 per hour and, unless otherwise agreed, the total charge for the actual time expended will be borne equally by the parties and due at the end of the scheduled time.

In order to make the most productive use of the scheduled time it would be helpful if each of you could provide for my review a summary of your client's position, the relevant facts and issues which will need to be addressed, and a copy of your client's financial affidavit if appropriate. All information provided in advance will be considered part of the mediation and therefore privileged and confidential.

I appreciate your confidence and look forward to working with you.

Sincerely,

A. Dean Hoolihan

ADH:jmh

DAVID M. WALL ATTORNEY AT LAW

PRESTIGE PLACE, SUITE 230 2600 MCCORMICK DRIVE

(727) 799-5251

CLEAR WATER, FL 33758

FAX (727) 796-0545

August 10, 1999

Robert N. Paske 1600 1st Street, Unit C Indian Rocks Beach, FL 33785

Re: Paske V. Paske

Dear Mr. Paske:

Enclosed herewith please find a copy of correspondence from Mr. Hoolihan, Esq., the mediator. He is requesting a summary of the client's position together with relevant facts and the issues to be addressed.

Perhaps it would save on the cost expenditure if you would put together a neat, concise summary which would include the facts and the issues.

I am more then happy to provide this if necessary, however, I offer you the first opportunity to do so. If you have any questions or concerns or request that ;I repare the summary please contact me so I know how to proceed.

Very ruy yours,

Davj/l'L Wall

DMW/jl enclosure (specified)

DAVID J. KURLAND - ATTORNEY AT LAW -

850 CLEARWATER.LARGO ROAD S.W.

CRIMINAL jaw LARGO, FLORIDA 33770 PERSONAL INJURY

TRIAL PRACTICE (813) 461.3555- FAX (813) 586.2731 WRONGFUL DEATH

November 26, 1999

David M. Wall, Esquire 2600 McCormick Drive, Suite 230 Clearwater, Florida 33759

RE: Paske post-dissolution proceedings; Case No. 90-005283-C1-022

Dear Mr. Wall:

Enclosed please find the Former Wife's Certificate of Compliance with attachments. Please advise when we can expect Mt Paske's mandatory disclosure. Also enclosed are copies of the production sent from the Pinellas County School Board pursuant to your Response to Notice of Production from Non-Party. Thank you.

Very sincerely,


Sheila Skeilie, Esquire

SKS:tms Enclosure PC: Mrs Liz Pratt

EXHIBIT "A"



(727) 799-6251

CLEAR WATER FL 33759

FAX (727) 796-0545

February 11, 2000

Robert N. Paske 1600 1st Street, Unit C Indian Rocks Beach, FL 33785

Re: Paske V. Paske

Dear Mr. Paske:

On Thursday, February 10th, I attended the hearing on my Motion for Judgment on the Pleadings. Although the legal discussion was certainly of interest to the Court, Judge Khouzam ruled at this stage of the proceedings that the Motion for Judgment on the Pleadings would be denied.

I amending the Answer to the Supplemental Petition for Modification to include at this point the Affirmative Defense of the prior Agreement.

In light of the fact that my prior Motion for Protective Order was based upon the ruling from this hearing, it now appears that mandatory disclosure will be due. I have enclosed herewith a copy of the documents that I need to be brought to this office as soon as possible. I have also enclosed a Financial Affidavit to be completed. I would like this also comØited within the next 10 to 14 days. If you have any questions p4ese contact me.

Very/ $2 yours,

Wall

DMW/jl enclosures (specified)


PRES11GE PLACE, SUITE 230 2600 MCCORMICK DRIVE

(727] 799-6251

CLEAAWATER, FL 3375S

FAX (727) 796-0545

February 11, 2000


Re: Paske v. Paske Circuit Civil No. 90-5283-CI-22

Dear David:

Enclosed herewith please find my Amended Answer with Affirmative Defense.

I am assuming we can agree to the filing of this document without the other formalities, hearing, stipulation, etc. Please advise.

Very truly yours,

David M. Wall




(727) 799-6251


FAX (727) 796-0545

June 12, 2000

Robert M. Paske 1600 1st street, Unit C Indian Rocks Beach, FL 33785

Re: Paske v. Paske

Dear Mr. Paske:

I have reviewed the file, your notes, and the discovery material and have acted accordingly. The information which I need from you at this time would be as follows:

a. A legible copy of your 1996 Federal Income Tax Return.

b. Better copies of 1996 - W-2 Statements, both of them, the one from the school system, and the one from what appears to be Electronic Data systems (7)

C. A better copy of the 1995 W-2 statements which appear to be three - one from the school system, one from Electronic Data Systems, and one from Computer Plus staffing.

Very truly yours,

David M. Wall

DMW/jl enclosures (specified) SIGNED IN ATIORNEY'S

ABSENCE TO AVOID DELAY IN MAILING


PRESTIGE PLACE, SUITE 230 2600MCCORMICKDRFVE CLEARWATER, FL 33759

(727) 799-6251 FAX (727] 796-0545

June 12, 2000


Re: Paske V. Paske Circuit Civil No. 90-5283-CI-22

Dear David:

On February 11, 2000, I furnished you with my proposed Amended Answer with Affirmative Defenses.

My correspondence at that time made the assumption that you would agreed to allow me to formally file the original, however, I have yet to hear from you.

At this time I have filed the original with the Court. I would like to assume you would agree to the Amended Answer as being properly filed, however, I need to have your most immediate response to know how to proceed.

Very truly yours,

David M. Wall


DAVID J. KURLAND — ATTORNEY AT LAW —

850 CLEARWATER-LARGO ROAD S.W.

CRIMINAL LAW LARGO, FLORIDA 33770 PERSONAL INJURY

TRIAL PRACTICE (813) 461-3555 - FAX (813) 586-2731 WRONGFUL DEATH

June 14, 2000


RE: Pratt v. Paske Case No: 90-005283-0-022

Dear Mr. Wall:

My client has asked me to make the following settlement proposal regarding the issues of child support and transportation costs pending in this matter.

As you maybe aware, Joeyhas two more visitations with Mr. Paske where he is accompanied to Florida by Mr. Pratt, Thanksgiving and Easter of2001. Beginning with summer-visitation in 2001, Joey will be traveling alone to Florida. Mrs. Pratt proposes that she will pay for Joey's airfare to Florida each time he visits if Mr. Paske would agree to pay child support in accordance with the attached child support guideline worksheet. Child support would commence on the first ofthe month following the signing of any agreement. However, Mrs. Pratt is now willing to give up any retroactive child support she may be owed and suggests that Mr. Paske pay an extra $200.00 per month toward the arrearage.

Please review this offer with your client and advise whether he is in agreement. Thank you for your cooperation in this regard.

Very sincerely,

ILtSJ1IJJP7sVAII3SMJ 114VJIE

By: Sheila Skellie, Esquire

SKS:tms

ri-i 55 -C (

IN THE CIRCUIT COURT OF THE SIXTH JUDICIAL CIRCUIT IN AND FOR PINIELLAS COUNTY, FLORIDA

ELIZABETH ANN PRATT, Petitioner,

and

Case No: 90-005283-CI-022

ROBERT MARK PASKE, Respondent,

CHILD SUPPORT GUIDELINES WORKSHEET

Number of Children (Section I): 1 FATHER MOTHER

Total actual income (Section III) $3,731.67 $4,791.66

Imputed income

Less total deductions (Section lV) $896,95 $1,147.46

Total Net Monthly Income $2,834.72 $3,644.20

COMBINED NET MONTHLY INCOME $6,478.92

Basic obligation (from chart) $1,170.00

Pro rate share of basic obligation 44% 56%

Pro rats financial responsibility $514.80 $655.20

Additions to basic obligation (Section II)

Pro rate share of 75% of child care costs equaling $ $0.00 $0.00 $0.00

Health insurance premiums of$ $0.00 $0.00 1 $655.20 --

$0.00

Statutory child support obligation $514.80

Adjustment for secondary residential parent paying child care expenses

$0.00

Adjustment for secondary residential parent paying child(r)'s health insurance premium

$0.00

Total Adjustments $0.00

Total child support responsibility of primary residential parent

$655.20

Total child support responsibility of secondary residential parent

$514.80


PRES11GE PLACE, SUUE 230 2800 MCCORMICK DRIVE

(727) 799-6251

CLE.APWATER, FL 33759

FAX (727) 786-0545

June 27, 2000


Re: Paske v. Paske Circuit Civil No. 90-5283-Cl-22

Dear David:

Thank you for your correspondence of June 14, 2000. Your proposal has been forwarded to Mr. Paske for his review and comment, however, I am not quite sure I understand the payment toward arrears. In light of the fact that in the same sentence you reference that Ms. Pratt is willing to give up any retroactive child support. Can you please clarify this statement.

I have a concern referencing the telephone deposition of Ms. Pratt. A memo to my file indicates that Ms. Pratt is making arrangements to have a notary present to swear her in at the taking of her deposition. Please be reminded that I scheduled the telephone deposition as a courtesy to you and your client, rather than insisting on her presence in the State of Florida as she is the party initiating these proceedings. I do not want to have any misunderstandings with respect to the notary arrangements, and therefore would indicate a head of time that if the notary is not present and available at the time of the taking of the deposition of Ms. Pratt, then you will agree to a continuance of the scheduled hearing if necessary.

Regarding the hearing, it was my understanding that we were going to attempt to obtain at least two (2) hours. I see from the Notice of Final Hearing we received in this office during my absence that only 1 hour has been scheduled for final hearing and an additional ½ hour on my Motion to Revisit Transportation Costs. I would like to see if we can iminediatelyreschedule this for a two hour time period. /1

Very ti1S yours,

Wall



850 CLEARWATERLAROO ROAD S.W.

CRIMINAL i.w LARGO, FLORIDA 33770 PERSONAL INJURY TRIAL PRACTICE (813) 461-3555 - FAX (813) 586-2731 WRONGFUL DEATH

June 28, 2000


RE: Prattv. Paske Case Jo: 90-005283-CI-022

Dear Mr. Wall:

My client has asked me to make the following settlement proposal regarding the issues of child support and transportation costs pending in this matter.

As you may be aware, Joey has two more visitations with Mr. Paske wdierde is accompanied to Florida by Mr. Pratt, Thanksgiving and Easter of 2001. Beginning with summer visitation in 2001, Joey will be traveling alone to Florida. Mrs. Pratt proposes that she will pay for Joey's airfare to Florida each time he visits if W. Paske would agree to pay child support in accordance with the attached child support guideline worksheet. Child support would commence on the first ofthe month following the signing of any agreement. However, Mrs. Pratt is not willing to give up any retroactive child support she may be owed and suggests that Mr. Paske pay an extra $200. OQ per month toward the arrearage.

Please review this offer with your client and advise whether he is in agreement. Thank you for your cooperation in this regard.

Very sincerely,

LAW OFFICE OF DAVID J. KIJRLAND

By: Sheila Skeffie, Esquire

SKS :tms

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PRESTIGE PLACE, BUtTE 230 2600 MCCORMICK DRIVE

(727) 799-6251 CLEAR WATER, FL 33753

FAX (727) 796-0545

June 29, 2000


Re: Paske v. Paske Circuit Civil No. 90-5283-CI--22

Dear David:

This will acknowledge receipt of your Memo dated June 28, 2000, that partially dealt with the taking of the deposition of your client.

I really want to have no confusion, Originally, I scheduled the deposition of your client to take place here in the State of Florida. I believe I an still entitled to do so initially as she is the petitioning party requesting affirmative relief here in the State of Florida. Correct me if I am wrong, but the request would thereafter be for you to have the deposition taken by telephone. It is my experience that if that takes place the obligation to insure the propriety of the telephone deposition is upon the party requesting same.

Perhaps in the matter of expediency and courtesy, I bypassed the first step, and agreed to schedule the deposition by telephone, however, again I reiterate that it is my understanding that the burden of the notary public is upon your client. It would be my understanding that if the deposition is postponed due to the lack of a notary public that unless the deposition can be rescheduled before final hearing, the final hearing would have to be continued.

I really don't anticipate nor expect problems in the taking of the deposition.

Very truly yours,

David N. Wall

DNW: j 1 cc: Robert Paske


PRES11GE PLACE, SUITE 230 2600 MCCORMICK DANE

(727) 789-6251

CLEARWATER, FL 33759

FAX (727) 796-0545

July 5, 2000



Dear David:

This will acknowledge receipt of your production to my Request for Production with respect to the above referenced matter.

In light of the August 16, 2000 final hearing date, I have scheduled a Motion to Compel with respect to the 1999 joint tax return.

I suggest that the case law makes it abundantly clear that your client's request for affirmative relief in this particular circumstance subjects her to disclosure of this tax return. Furthermore, it is related to the substance of the former agreement, and your own pleadings.

Unless you have any suggestions other than a flat refusal to comply, please accept this as my good faith attempt to settle and resolve this issue prior to the actual filing of my Motion to Compel.

Very truly yours,

David M. Wall


SENT BY: JuDGE NELLY KMOUZAM; 727 4645052; AUG-7-00 1:13PM; PAGE 1/2

NNew WE

$tate of Almem

1 ixtIj MuMciaL ircuil of Siba couwrme Or PWJnLAS AND PASCO

PNflIIM COUNTY COUflTSOUSZ 315 COURT STRT

?IflLT N XHOUZAW CtflRWATfl. flORWA 5*750 )U.Lx K JOW4SON cacWT JVDGZ (737) 404-1 JUDICIAL AS*STANT

August 7, 2000

PLEASE DELIVER THE FOLLOWING PAGES:

TO: David Kurland, Esq. (727) 586-2731

David Wall, Esq. (727) 796-0545

FROM: Michelle Johnson, Judicial Assistant CITY: Clearwater, Florida TELEPHONE: (727) 464-3232 FAX NUMBER: (727) 464-5052

TOTAL NUMBER OF PAGES INCLUDING THIS COVER PAGE: 2

MESSAGE:

IF YOU DO NOT RECEIVE ALL PAGES, PLEASE CALL THE ABOVE NUMBER AS SOON AS POSSIBLE.

DAVID M. WALL AUORNEf AT LAW

PRESTIGE PLACE. SUITE 230 2800 MCCORMICK DRWE

(727) 799-6251


FAX (727) 796-0545

September 13, 2000



Dear David:

I need to schedule the deposition of Ms. Pratt with respect to my Motion for Contempt. Can we set it up by telephone with your client's cooperation as was done the last time?

Very truly yours,

David N. Wall




(727) 798-6251


FAX (727) 796-0545

September 27, 2000

Robert M. Paske 1600 1st Street, Unit C Indian Rocks Beach, FL 33785

Re: Paske V. Paske

Dear Mr. Paske:

This will acknowledge receipt of the copies of the correspondence you recently provided to my office.

In the August 31st letter from "Liz" she references Greg's last letter. The only letter I have from Greg is a letter subsequent to the date, September 10, 2000. Can you please provide me with a copy of his correspondence to wh2i4h she refers.

Very

David W. Wall

DMW/jl

10/2/00

David,

You requested a letter from Greg that was referenced in Liz's letter dated August 31. I've enclosed it - it is the one dated August 20, 2000.

I thought I would enclose a copy of all the correspondence we have had since we have started writing instead of speaking on the phone. That way, you have it all, and won't be surprised by any of it, if it comes up in our court hearing.

Thanks.

-Bob

RILEY HENRY C ATTORNEYS AT LAW L. Pjiiv Sown St Mr. Robert...

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