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Re:  Crown v. King, Case Number:


Dear XXXX:


I am in receipt of your September 2, 2016 email.  My client’s responses are as follows:


  1. Dog


My client is aware that a personal injury attorney sent a letter to the child’s sister regarding the dog bite.  My client is saddened by your client’s decision, but not enraged.  This was an unfortunate incident as stated by the Judge that heard your client’s emergency motion.  No one has harassed your client or attempted to contact her to the best of his knowledge.  My client has taken the child over to the house one time as recommended by the Judge who thought it would be beneficial for the child.  My client reassured the child it was safe to visit his sister’s house as the dog was removed from the residence.


  1. Tutoring Books


Your client is twisting the story about the tutoring books.  My client told your

client the reason he was only giving half of the tutoring books was in consideration for the child so it was not necessary for him to carry 2 book bags to school on Wednesdays and to ensure the child has equal amount of the tutoring books at their homes.  The child’s book bag is already at capacity with his school books and change of clothes.   My client told the Mother that both parties would need to purchase additional books, if they wanted.  My client even forwarded a picture of the books showing her the book titles on September 1, 2016 (see attached photo of child’s book bag and text message sent to your client).


  1. Emergency Contact Form at School


My client has always had your client’s contact information on all forms at the

school.  Your client was informed by a school employee that both phone numbers would be called (both his and hers) in case of an emergency.  That was your client’s concern when the parties were both at the school that she would not be contacted.  Your client’s information was always on the form.


Since the parties were at the school your client took it upon herself to fill out and replace the original emergency contact form naming only herself to be contacted in case of an emergency.  Please immediately have her go back to the school and add my client’s name to the form (see copy of new form filled out by your client).  As far as my client being rude and nasty it was just the opposite.  Your client started name calling on school grounds and her behavior was unruly.  After her behavior my client informed her that he would no longer have any verbal conversations with her (see attached text message).


  1. Missed Nightly Phone Call


The parties got home late due to weather and was assisting the children with

their homework.   The child was finished doing his homework and was playing a game on the Father’s phone while the Father was still assisting his daughter with her homework.  The child answered the phone when your client called and placed the phone on speaker as the child does when the Father calls him at the Mother’s residence.  My client has always made sure the child has had daily communication with the Mother during his timesharing.


  1. Pick Up/Drop off Times


The first Court order gave specific pick up and drop off times.  On the modified

Order there was no specific drop off and pick up times.  This was left for the parents to determine what times would be best for the child.  Since the entry of the Order in 2011 the parties agreed the Mother would drop off the child on Sunday mornings and the Father would take him to school on Wednesday mornings.  This is the schedule both parties agreed to and been exercising for over 5 years.





Very truly yours,


Larry D. Schott


Enclosures as noted




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This document is a sample pleading related to a specific set of facts and circumstances and should not be used or relied upon for any family law matter. This document is being provided for illustrative purposes only. We recommend and urge you to consult with an experienced divorce lawyer for professional advice as each case is unique.

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